Cfatf Fur Suriname 11 PP

CARIBBEAN FINANCIAL
ACTION TASK FORCE
Suriname Eleventh Follow-up Report
Summary: Detailed exit report of Suriname
Meeting Date: May 31th 2017
Port of Spain, Trinidad and Tobago
2017 CFATF. All rights reserved.

No reproduction or translation of this publication may be made without prior written permission. Requests for
permission to further disseminate reproduce or translate all or part of this publication should be obtained from the
CFATF Secretariat at cfatf@cfatf.org
May 31, 2017
Table of Contents
I. INTRODUCTION ....................................................................................................... 4
II. MAIN CONCLUSION AND RECOMMENDATIONS TO THE PLENARY ...... 6
Core Recommendations: ................................................................................................. 6
Key Recommendations: .................................................................................................. 8
Conclusion .......................................................................................................................... 9
III. OVERVIEW OF PROGRESS MADE BY SURINAME ........................................ 9
Overview of the main changes since the adoption of the Mutual Evaluation Report
(MER) ............................................................................................................................. 9
IV. DETAILED ANALYSIS OF COMPLIANCE WITH THE CORE
RECOMMENDATIONS .................................................................................................. 11
Recommendation 1 PC .............................................................................................. 11
Recommendation 1- overall conclusion........................................................................ 13
Recommendation 5 NC .............................................................................................. 13
Recommendation 5 overall conclusion ......................................................................... 17
Recommendation 10 PC ............................................................................................ 17
Recommendation 10 overall conclusion ....................................................................... 17
Special Recommendation II overall conclusion ........................................................... 20
Special Recommendation IV - NC ............................................................................... 20
Special Recommendation IV overall conclusion .......................................................... 20
V. DETAILED ANALYSIS OF COMPLIANCE WITH THE KEY
RECOMMENDATIONS .................................................................................................. 21
Recommendation 3 - PC ............................................................................................... 21
Recommendation 4 - PC ............................................................................................... 21
Recommendation 23 - NC ............................................................................................ 22
Caribbean Financial Action Task Force (CFATF) Page 2 of 171

May 31, 2017

Recommendation 26 - PC ............................................................................................. 24
Special Recommendation I - NC .................................................................................. 29
Special Recommendation I overall conclusion ............................................................. 29
Special Recommendation III - NC ................................................................................ 29
Special Recommendation V - NC ................................................................................. 32
Special Recommendation V overall conclusion ........................................................ 32
VI. ANALYSIS OF MEASURES TAKEN IN RELATION TO OTHER
RECOMMENDATIONS RATED NC OR PC ................................................................ 33
PREVENTIVE MEASURES - FINANCIAL INSTITUTIONS ...................................... 33
PREVENTIVE MEASURES DESIGNATED NON-FINANCIAL BUSINESSES AND
PROFESSIONS ................................................................................................................ 37
LEGAL SYSTEMS & RELATED INSTITUTIONAL MATTERS ................................ 37
ANNEX 1 SUSPICIOUS TRANSACTION REPORTS AND OTHER REPORTS .... 41
ANNEX II ML & FT INVESTIGATIONS; PROSECUTIONS AND CONVICTIONS
........................................................................................................................................... 42
ANNEX III MUTUAL LEGAL ASSISTANCE OR OTHER INTERNATIONAL
REQUESTS FOR CO-OPERATION ............................................................................... 43
ANNEX IV OTHER ACTION ...................................................................................... 45
ANNEX V TRAINING ................................................................................................. 46
Matrix ................................................................................................................................ 47

May 31, 2017
SURINAME: ELEVENTH FOLLOW-UP REPORT UPDATE AND FULL ANALYSIS
I. INTRODUCTION
1. The third round MER of Suriname was adopted in October 2009, in Curacao, and Suriname
was placed in expedited follow-up. Suriname reported back to the CFATF in May 2011,
(first follow-up report); May 2012, (second follow-up report); November 2012, (third
follow-up report); May 2013, (fourth follow-up report); May 2014, (fifth follow-up report);
November 2014, (sixth follow-up report); May 2015, (seventh follow-up report);
November 2015, (eight follow-up report); June 2016, (ninth follow-up report); and
November 2016, (tenth follow-up report).
2. This report is based on the CFATF procedure for removal from regular follow-up as
agreed1 by the CFAFT plenary in May 2014. Suriname has indicated that it is of the opinion
that it had met the criteria necessary for removal from regular follow-up. It contains a
detailed description and analysis of the actions taken by Suriname in respect of the core
and key Recommendations rated partially compliant (PC) or non-compliant (NC) in the
mutual evaluation, as well as a description and analysis of the other Recommendations
rated PC or NC.
3. The analysis of this report was predicated on the basis of information provided by Suriname
and is a desk evaluation that focused on Recommendations rated PC/NC, which means that
only a part of the AML/CFT system was reviewed. The analysis consisted mainly looking
at the main laws, regulations, directives, state decrees, ministerial decrees along with other
material provided by Suriname. As this is a desk-based review, the level and nature of
information provided and accepted in many instances is inherently different to that which
would have been accepted during an onsite visit. Consequently, the conclusions of this
report do not prejudge the results of any future assessments as they are based on
information that was not verified through an onsite process.
The Legal and Regulatory Framework
1
According to the decisions by the May 2014 Plenary, countries can apply to exit the follow-up process in the following
cases:
a. Countries who have achieved the level of C/LC in all of their Core and Key Recommendations that were
rated PC/NC in their MERs to apply to exit the FUP ; or
b. Countries that have achieved the level of C/LC in all their Core Recommendations, but have one (1) or more
Key Recommendations that were rated PC/NC and still have not achieved the level of C/LC in those
recommendations to apply to exit once they have achieved substantial compliance (the large majority of
non-Core and Key Recommendations have been addressed) in their non-Core or Key Recommendations that
were rated PC/NC in their MER.

May 31, 2017
4. Surinames AML/CFT legal and regulatory framework are based on several laws
(including Presidential Decrees and Ministerial Decrees). The main laws are the MOT and
the WID. The relevant laws are discussed, in detail, at section IV of this report.
5. Suriname was rated PC or NC on the following Recommendations:
Table 1: Ratings for Core, Key and other Recommendations
PARTIALLY COMPLIANT (PC) NON-COMPLIANT (NC)

Core Recommendations
R.1 (ML offence) R.5 (CDD)
R.13 (Suspicious transactions reporting)
R.10 (Record keeping)
SR. II (TF Criminalization)
SR.IV (Suspicious transactions reporting)
Key Recommendations
R. 3 (Confiscation and provisional R. 23 (Regulation; supervision and monitoring)
measures) SR. I (Implement UN Instruments)
R. 4 (Secrecy laws) SR. III (Freeze and confiscate terrorist assets)
R. 26 (The FIU) SR. V (International cooperation)
R. 35 (Conventions)
R. 40 (Other forms of cooperation)
Other Recommendations
R. 14 (Protection & no tipping-off) R. 6 (Politically exposed persons)
R. 18 (Shell banks) R. 7 (Correspondent banking)
R. 20 (Other NFBP & secure transaction R. 8 (New technologies & non-face-to-face
techniques) business)
R. 25 (Guidelines & Feedback) R.9 (Third parties and introducers)
R. 27 (Law enforcement authorities) R. 11 (Unusual transactions)
R. 30 (Resources, integrity and training) R. 12 (DNFBP R.5, 6, 8-11)
R. 37 (Dual criminality) R. 15 (Internal controls, compliance & audit)
R. 38 (MLA on confiscation and freezing) R. 16 (DNFBP R.13-15 & 21)
R. 17 (Sanctions)
R. 19 (Other forms of reporting)
R. 21 (Special attention for higher risk countries
R. 22 (Foreign branches & subsidiaries)
R. 24 (Regulation, supervision and monitoring)
R. 29 (Supervisors)
R. 32 (Statistics)
R. 33 (Legal persons beneficial owners)
SR. VI (AML requirements for money/value
transfer services)
SR. VII (Wire transfer rules)
SR. VIII (Non-profit organisations)
SR. IX (Cross Border Declaration & Disclosure)

May 31, 2017
II. MAIN CONCLUSION AND RECOMMENDATIONS TO THE PLENARY
Core Recommendations:
6. Recommendation 1: At the time of the onsite the full gamut of designated categories of
offences were not criminalized. However, Suriname addressed this by criminalizing
terrorism and TF, through the enactment of O.G. 2011 no 96, and insider trading and
market manipulation, through the enacting of the Act on Capital Markets (O.G. 2014 no
53). Now that all designated categories of offences have been designated as predicates in
Suriname R. 1 has been implemented to a level comparable to LC.
7. Recommendation 5: At the time of the onsite the WID Act did not provide for an adequate
and solid framework that imposes the required obligations on FIs. The scope of the WID
Act was limited to basic customer identification requirements and did not contain the broad
range of customer due diligence (CDD) measures anticipated by the FATF
Recommendations. Additionally, the need for the establishment of the identity of the
ultimate beneficial owner(s) was not elaborated in the WID Act. The enactment and
bringing into force of the amended WID Act and the MOT Act in 2012 have addressed
those deficiencies so that R. 5 has been brought to the level that is comparable to an LC.
8. Recommendation 10: Amendments to the WID and specifically art 8 sub 1-2 now ensures
that service providers are bound to maintain records in an accessible manner, even after the
statutory retention period of seven (7) years. There is also now a general requirement for
these records to be maintained in an accessible manner. This action has had the effect of
bringing the level of R. 10 to a level comparable to C.
9. Recommendation 13: The criminalization of all designated categories of offences,

including terrorism and TF; properly particularizing the information which is to be
submitted to the FIUS when FIs report STRs; ensuring that there is a clear timeline within
which STRs are to be submitted to the FIUS, following the determination of a suspicion;
and through the ongoing raising of awareness by the reporting entities. This action has had
the effect of raising the level of compliance with R. 13 to a level comparable to an LC.
10. Special Recommendation II: SR. II was deficient owing to the non-criminalization of TF.
Now that TF has been criminalized, SR. II has been implemented to a level comparable to
an LC.
11. Special Recommendation IV: Owing to art. 12 sub 1 of the MOT and the SDIUT there is
now a direct reporting requirement, which includes the reporting of attempted
transactions irrespective of the amount of funds. This ensures that the level of
compliance with SR. IV is equivalent to an LC.

May 31, 2017

May 31, 2017
Key Recommendations:
12. Recommendation 3: Suriname now has the legal basis upon which to confiscate TF related
assets. Therefore, the level of compliance is brought up to that equivalent to an LC.
13. Recommendation 4: R. 4 continues to be deficient because the MOT Act is silent on the
Gaming Supervision and Control Institute, as supervisory authority, in Suriname, ability to
share information.
14. Recommendation 23: The deficiencies for R. 23 were all addressed through legislation.
Art 22 of the MOT Act was enacted to specifically entrust the CBS as the Supervisory
Authority for service providers; Chapter 2 of the MTOSA, art 3.1 has empowered the CBS
with exclusive authority to grant licences to legal entities wishing to carry on the business
of a money transaction office; and art. 10 of the Capital markets Act places all market
participants within the capital market under the supervision of the CBS. R. 23 is now
implemented to a level equivalent to an LC.
15. Recommendation 26: Six of the nine deficiencies were addressed whilst the remaining
three are subject to ongoing implementation. The FIUS has increased manpower and is
now an independent institute within the Ministry of Justice and Police. The unit was moved
to secured premises in the business district of Suriname and acquired computer hardware
to store its information. The FIUS has also issued guidance to reporting entities and began
publishing its annual reports on its website. R. 26 is now implemented to a level which is
equivalent to a LC.
16. Recommendation 35: The deficiencies for R.35 were based on the Vienna and Palermo
Conventions not being fully implemented. Suriname acceded to the UNs International
Convention for the Suppression of the Financing of Terrorism on July 18, 2013 and on
May 21, 2004, enacted the International Sanctions Act to address the aspects of freezing of
funds related to UN resolution 1267 and 1373. R.35 is now implemented to a level which
is equivalent to a LC.
17. Recommendation 40: All six deficiencies for R. 40 have been addressed through:
amendments to the MOT, the enactment of art. 46 of the BCSSA; amendments to the Act
on Disclosure of Unusual Transactions to give the FIUS jurisdiction over the processing of
TF related disclosures. R.40 is now implemented to a level which is equivalent to a LC.
18. Special Recommendation I: Because the deficiencies for SR. I and R. 35 were identical
the noted action which addressed the gaps for R. 35 are relevant here. SR. I is now
implemented to a level which is equivalent to a LC.
19. Special Recommendation III: The mechanisms necessary to implement all the essential
criteria with the exception of III.5 have been put in place. The freezing of assets in
accordance with S/RES/1267(1999) and S/RES/1373(2001) is enabled through Art. 2 of
the International Sanction Act; The State Decree (O.G. 2016 no 131) has been enacted to

May 31, 2017
give effect to, the actions initiated under the freezing mechanism of other jurisdictions; A
Council on International Sanctions has also been established as a legal entity with
responsibility for, among other things, executing decisions sent to it by the Minister;
procedures have been put in place for considering delisting requests and unfreezing of
funds; procedures have also been put in place for unfreezing the funds or other assets of
persons or entities inadvertently affected by a Surinames freezing mechanism; The
Council is authorized to provide access to frozen funds for: payments of necessary living
expenses, medical treatment, the fulfillment of long-term financial obligations. SR. III is
now implemented to a level which is equivalent to an LC.
20. Special Recommendation V: The lone deficiency relating to the criminalisation of all
designated predicate offences and terrorism financing was addressed. SR. V is
implemented to a level which is equivalent to an LC.
Other Recommendations:
21. Suriname has made significant progress in addressing the deficiencies in its non-core and
key Recommendations that were rated PC/NC. The Jurisdictions application for removal
from the third-round follow-up process is based on its compliance with the Core and Key
Recommendations that were rated PC/NC. Accordingly, this report will only provide a
limited analysis the Other Recommendations which is detailed at section VI of this report.
Conclusion
22. This detailed analysis of Surinames action to close the deficiencies noted in its 3rd MER
provides an overview of the progress relating to all Core and Key Recommendations that
were rated PC/NC in the 2009 MER. This analysis indicates that Suriname has addressed
all Core and Key Recommendations rated PC/NC (R. 1, 3, 5, 10, 13, 23, 26, 35, 40, SR. I,
II, III, IV & V) to a level comparable to at least an LC. Following the presentation of this
report, the Plenary agreed that Suriname had sufficiently met the criteria to exit the CFATF
third-round follow-up process. The Jurisdiction therefore exited the follow-up process.
III. OVERVIEW OF PROGRESS MADE BY SURINAME
Overview of the main changes since the adoption of the Mutual Evaluation Report
(MER)
23. Suriname began its legislative reform by enacting two Acts namely: the O.G. 2011 no 96,
which is an Act amending the Criminal Code; the Firearms Act; and the Act on the
Disclosure of Unusual Transactions, in connection with the criminalization of terrorist
crimes and their financing. This Act was published in the State Gazette of 29th July, 2011,
and came into force on 30th July, 2011; and O.G. 2011 no 155 which is a new Banking and
Credit System Supervision Act (BCSSA) that came into force on 23rd November, 2011.

May 31, 2017
24. Suriname also amended the Wet Melding Ongebruikelijke Transacties (SB 2002, 65),
MOT (Act on the Reporting of Unusual Transactions) and the Wet Identificatieplicht
Dienstverleners (SB 2002, 66), WID (Act on the identification requirements for Service
Providers). Both amendments were adopted by the Jurisdictions Parliament on July 17,
2012 and entered into force on August 9, 2012.
25. On October 29, 2012, Suriname brought the Money Transaction Offices Supervision Act
2012 (MTOSA) into force. The main objective of the MTOSA is to guarantee the integrity
of the Surinamese financial system, as well as to prevent money laundering and the
financing of crimes of terrorism. It provides that the business of a money transaction office
(MTO) must be linked to a licence issued by the Central Bank of Suriname (CBS). The
MTOSA also assigned supervisory duties for MTOs to the CBS.
26. On August 15, 2013, the State Decree on Indicators of Unusual Transactions (SDIUT) was
brought into force as (O.G.2013 no.148). Provisions of this law positively affected: Recs.
13, 26 and SR. IV, by including a requirement for attempted unusual transactions to be
reported.
27. On May 21, 2014, the Act on Capital markets came into force as (O.G. 2014, no 53).
Provisions of this law positively affected Recs. 1, 13, 23, 37, 38 and SRIV. Also on May
21, 2014 the International Sanction Act came into force (O.G. 2014 no 54). This law was
intended to lay down the general framework to comply with the international obligation,
specifically the resolutions established by the United Nations Security Council relating to
threats or disruption to international peace and security (UN resolution 1267 and 1373).
The measures to be implemented, based on this law, included the freezing of terrorist funds.
28. On April 1, 2015, the CBS amended the AML/CFT regulations. Provisions of this
amendment positively affected Recs. 15, 21, 23 and SRVII. On February 29, 2016, Act
(O.G. 2016 no. 31) was enacted, and brought into force on March 3, 2016, to amend the
International Sanctions Act, (O.G. 2014 no. 54). This law established a Council, as a legal
entity, on International Sanctions, with responsibility of supervising all service providers
for compliance with the International Sanctions Act. This amendment positively affected
SR.III.
29. On February 29, 2016, Act (O.G. 2016 no. 32) was enacted, and brought into force on
March 3, 2016, to amend the WID Act. This law is directly related to the CDD obligations
applicable in higher risk situations and was intended to make enhanced customer due
diligence mandatory for Surinames non- profit organizations. This law did not have any
positively effect on SR. VIII.
30. On February 29, 2016, State Decree (O.G. 2016 no 34) was enacted with the overarching
intent to implement article 2 section 1 of the International Sanctions Act (O.G. 2014 no.
54) and in complying with the international obligations as contained in the Resolutions
1267, 1333, 1373, 1452, 1735, 1988, 1989, 2160, 2161 and 2170 of the Security Council
of the United Nations. This amendment positively affected SR. III.

May 31, 2017
31. On July 29, 2016, Suriname amended the Surinamese Commercial Code (O.G. 2016 No.
103) to abolish the issuance of new bearer shares and create an opportunity for existing
bearer shares to be converted to registered shares. This action positively affected
Recommendation 33.
32. On October 13, 2016, the president of the Central Bank of Suriname (CBS) issued new
AML/CFT Directives to replace the April 2015 AML/CFT Directives. This action
positively affected Recommendation 9.
33. On October 17, 2016, the President of Suriname issued a State Decree (O.G. 2016 no 131),
which is inherently concerned with providing further details on the rules for implementing
the jurisdictions freezing mechanism. These mechanisms were established through the
International Sanctions Act S.B. 2014 no. 54, as amended by S.B. 2016 no. 31. The State
Decree introduces procedures for the de-listing and freezing and unfreezing of funds of
natural and legal persons. On October 25, 2016, procedures were laid down by the Minister
of Foreign Affairs. This action positively affected Recommendation 35, and Special
Recommendations I and III.
34. On October 25, 2016, Suriname enacted legislation (the WOTS Act) as O/g/ 2016 no 132,
containing rules concerning the take-over of the execution of foreign criminal court
decisions and the transference of the execution of the Surinamese criminal court decisions
to the foreign country. This action positively affected Recommendation 35 and Special
Recommendation I.
IV. DETAILED ANALYSIS OF COMPLIANCE WITH THE CORE

RECOMMENDATIONS
Recommendation 1 PC
R. 1 (Deficiency 1): Not all designated categories of predicate offences are covered in
the absence of the criminalization of terrorism and financing of terrorism and
insider trading and market manipulation in Suriname penal legislation.
35. Suriname criminalized terrorism by enacting O.G. 2011 no 96, (art.1A. Art.1C (2)) and
the financing of terrorism by adding the paragraph k with the following definition:
Financing of terrorism:
i. the intentional acquisition or possession of monetary instruments or objects
with monetary value for purposes of committing a terrorist crime;
ii. the intentional acquisition of monetary resources for the commission of a
terrorist crime; or
iii. the provision of monetary or material support for the acquisition of money or
objects for an organization that intends to commit a terrorist crime.

May 31, 2017
36. Insider trading and market manipulation have been criminalized through the enactment of
the Act on Capital Markets (O.G. 2014 no 53). At art 1 (General Provisions), of the said
Act, insider trading is defined (art 1 sub (m)) whilst market manipulation is defined at art
1 sub (n). Insider trading is defined as knowledge of specific inside information which
has a direct or indirect bearing on a securities-issuing institution whose securities are
traded on the stock exchange for which the holder has been granted a license, or which
pertains to trading in such securities, where such information has not been brought into
the public domain, the disclosure of such information would impact significantly on the
price of the securities or on the price of securities deriving therefrom. Even though this
definition for insider trading appears to refer to a definition for insider information, at art
19 (Market Abuse), it is prohibited for any person to make use of inside information for
their own benefit or for the benefit of a third person where such a person acquired the inside
information in his capacity either as: a member of the issuers board of executive directors,
management or supervisory bodies; through his participation in the issuers capital; through
his access to the information owing to his work, profession or position or for other reasons;
or through criminal activity. Based on the definition of insider trading at art 1 sub (m) it
appears that the mere knowledge of insider information would constitute insider trading
once a person who has such knowledge engages in the conduct prohibited by art 19.
37. As for market manipulation, art 1 sub (n) defines a situation where there is deliberate
interference in the supply or demand for securities through the dissemination of incorrect
or misleading information or through transactions or trade orders which give misleading or
incorrect signals or even where one or more persons act in concert to maintain the price of
a security at an artificial or incorrect level. Art 21 prohibits any person from engaging in
market manipulation. Under art 34 (Penalty Provisions), both insider trading and market
manipulation are deemed to be criminal offenses and a person committing either is liable
to be sentenced to a maximum term of imprisonment of two years and to a maximum fine
of SRD 5 million. R1 deficiency 1 is sufficiently addressed.
R. 1 (Deficiency 2): It is virtually impossible to do any assertion with regards to the

effectiveness and efficiency of the systems for combating ML, due to the lack of
comprehensive and reliable (annual) statistics.
38. The maintenance and availability of comprehensive statistics are addressed at

Recommendation 32. (click here to read the text of Recommendation 32).
R. 1 (Deficiency 3): Evidentiary requirements for autonomous ML still untested

(effectiveness issue).
39. The text of the ML provision adequately covers all elements required by the international
standards and all the designated categories of offences are now criminalised in Suriname.
This deficiency refers to the implementation of these elements which can only be assessed
through an analysis of data and other information on prosecutions, convictions, penalties,

May 31, 2017
freezing/seizing and confiscation etc. Suriname has not as yet produced such data or other
information therefore such an analysis cannot be conducted.
Recommendation 1- overall conclusion
40. There were three deficiencies noted by the Assessors, two of which were hinged on the
Jurisdictions ability to show that the ML provisions were being implemented. The other
deficiency was related to the non-criminalization of some designated categories of
offences. Now that the missing offences have been criminalized, the full scope of ML and
its predicates have been addressed, therefore the compliance with this Recommendation is
up to a level comparable at minimum to an LC.
Recommendation 5 NC
41. The Assessors made thirteen recommendations aimed at closing the gaps they discerned in
Surinames AML/CFT infrastructure. Suriname has responded by amending the WID Act
and the MOT Act to specifically close these gaps. The analysis of these amendments and
the effect they have had towards closing those gaps are detailed below:
R.5 (Deficiency 1) All financial institutions should be fully and effectively brought
under AML and CFT regulation and especially under the broad range of customer
due diligence requirements.
42. The preface to the CBS 2012 Directives has noted that the bank, in its capacity as
supervisor of financial institutions, has decided to issue the new directives to support
Surinames AML/CFT legislation.
CBS Directives as Other Enforceable means (OEM)
43. Under art 16.1 of the Banking and Credit System Supervision Act 2011(BCSSA) the
CBS is authorised to issue guidelines with regard to the administrative and management
organization of credit institutions, including financial administration and internal control,
to their business operations to combating of money laundering and the financing of
terrorism. At art 17 of the BCSSA, if the CBS discovers that a credit institution is not
following the guidelines, it may instruct the relevant credit institution, by registered letter,
to take the necessary measures or to follow a particular line of conduct in accordance with
CBS instructions. If no satisfactory response is forthcoming from the credit institution
within a period determined by the CBS, or if the CBS determines that its instructions has
not been satisfactorily complied with, then it may place the defaulting credit institution
under undisclosed custody requiring it to carry out its activities only subject to approval by
the CBS, through persons appointed by the CBS. At art 56 of the BCSSA, the CBS is
authorized to impose a financial penalty on the credit institution for non-compliance,
including non-compliance with article 16. The amount of all such penalties is set by order
or decree, on the understanding that the penalty payable per infringement may not exceed
SRD 1,000,000 and under no circumstances can such penalty exceed 25 percent of the

May 31, 2017
annual profit, as evidenced by the most recent certified financial statements issued by the
external auditor in respect of the credit institution that was penalized. Ultimately, art 11 of
the BCSSA gives the CBS the authority to revoke the license of a credit institution if that
credit institution fails to observe the guidelines issued in accordance with the said BCSSA.
R.5 deficiency 1 is sufficiently addressed.
R.5 (Deficiency 2) The definition of financial activities should be updated in

accordance with the definition of financial activities in the FATF Methodology.
44. According to art. 1 c of the WID and art.1 c of the MOT financial services has the
meaning of the professional or commercial performance of one or more of the following
activities:
a. C. 10 - accepting deposits and other withdrawable funds from the public;
b. C.11 granting of loans;
c. C.12 - financial leasing, with the exception of consumer-relating leasing;
d. C.8 - performing national or international financial transfers;
e. C.13 - issuing and managing of payment instruments other than cash, which in any
case includes credit cards, debit cards, cheques, travelers cheques, payment orders,
electronic and non-electronic money orders and electronic money;
f. C.14 - furnishing of financial guarantees and sureties;
g. C.16 - trading in the following:
b. money market instruments, such as cheques, bills of exchange and derivatives;
c. transferable securities;
d. futures market commodities;
a. C.17 - participating in securities dealing and related financial services;
b. C.18 - receiving in safekeeping and managing of cash or liquid securities for third
parties;
c. C.19 - other forms of investment, administration or management of funds or cash
for third parties;
d. C.5 - taking out, surrendering and payment, as well as acting as a broker in taking
out, surrendering and payment of a life insurance agreement and other investment-
linked insurance products;
e. C.7 - buying or selling Suriname dollars (SRDs) or foreign currency;
45. Whilst the inclusion of the financial activities listed above now bring Suriname closer to
fully implementing the Assessors recommendation, it must be noted that the activity of
Individual and collective portfolio management has not been included and Suriname has
not indicated whether the exclusion of this activity was predicated on the limited
occurrence of that activity in the jurisdiction, or whether there was, based on analyses, little
risk of money laundering activity occurring through the provision of this service.

May 31, 2017
R.5 (Deficiency 3): Financial institutions should be required to undertake full CDD
measures when carrying out occasional transactions that are wire transfers in
circumstances covered by the Interpretative Note to SR VII or occasional transactions
above the applicable threshold of USD/EUR 15.000.
46. At art. 2 sub B of the WID Act (O.G. 2016 no 33) there is the Duty to provide proof of
identity when carrying out non-recurring transactions (including wire transfers) of a joint
value as established in the SDIUT. The SDUIT is however silent on a specific threshold.
This deficiency is not sufficiently addressed.
R.5 (Deficiency 4): The requirement to undertake CDD measures in cases where there
is a suspicion of terrorist financing and in cases where there are doubts about the
veracity or adequacy of previously obtained customer identification data.
47. This deficiency has been closed by virtue art. 2 sub 2d and 2e of the WID. Article 2 sub 2
d addresses doubts surrounding the reliability of previously obtained client information
whilst article 2 sub 2 e is concerned with clients who are at risk of being involved in terrorist
financing. R.5 deficiency 4 is sufficiently addressed.
R.5 (Deficiency 5): The requirement to verify the legal status of legal arrangements
like trusts and understand who is (are) the natural person(s) that ultimately owns or
control the customer or exercise(s) effective control over a legal arrangement such as
a trust.
48. It is noted at paragraph 610 of the MER that Suriname Does not know trusts or other legal
arrangements R.5 deficiency 5 is sufficiently addressed.
R.5 (Deficiency 6): The requirements regarding identification and verification of the
beneficial owner for legal persons, including the obligation to determine the natural
persons who ultimately own or control the legal person.
49. Art 1of the WID has defined ultimate beneficial owner as the natural person who owns,
has control over or exercises control over a legal entity. At art 2 sub 1 b of the WID there
is the requirement for service providers to perform client screening, which in the case of
ultimate beneficial owners includes identifying the beneficial owner and verifying his
identity to such an extent that the service provider is convinced of the identity of the
beneficial owner. R.5 deficiency 6 is sufficiently addressed.
R.5 (Deficiency 7): The obligation to obtain information on the purpose and intended
nature of the business relationship.
50. This deficiency has been addressed because the client screening obligations under the
WIDs amendment Duty to provide Proof of Identity includes, at art. 2.1c, an obligation
to determine the object and intended nature of the business relationship. R.5 deficiency 7
is sufficiently addressed.

May 31, 2017
R.5 (Deficiency 8): No specific requirement to perform ongoing due diligence on

business relationships.
51. This gap has been specifically closed due to the WIDs amendment Duty to provide Proof
of Identity where at art. 2.1d service providers are mandated to perform on-going checks
of the business relationship to ensure that the transactions correspond with the knowledge
that the service provider has of the client and the ultimate beneficial owner. R.5 deficiency
8 is sufficiently addressed.
R.5 (Deficiency 9): Performing enhanced due diligence on higher risk categories of
customers, business relationships or transactions.
52. At art 4 of the WID amendment, service providers are required to carry out a more
stringent client screening process if the nature of a business relationship or transaction
entails a higher risk of money laundering or terrorist financing. This more stringent client
screening is required to be performed both prior to the establishment of, and during the
business relationship in the specific situations noted at art 4 sub a - h. R.5 deficiency 9 is
sufficiently addressed.
R.5 (Deficiency 10): There should be some consideration/assessment made based on

which there is a satisfaction about compliance with the Recommendations by
countries which are currently seen as compliant without any doubt.
53. Art 3 sub 1 of the WID requires service providers to tailor their client screening based on
the risk sensitivity for ML and TF and the type of customer, business relationship, product
or transaction. R.5 deficiency 10 is sufficiently addressed.
R.5 (Deficiency 11): There are no general requirements to apply CDD measures to
existing customers on the basis of materiality and risk.
54. The analysis for R.5 deficiency ix above is also applicable here. R.5 deficiency 11 is
R.5 (Deficiency 12): When regulating the identification and verification of beneficial
owners, a requirement to stop the financial institution from opening an account,
commence business relations or performing transactions when it is unable to identify
the beneficial owner satisfactorily.
55. At art 2a sub 3 and 4 there is the provision preventing a service provider from entering
into a business relationship or executing a transaction if that service provider is either
unable to perform client screening or if client screening does not result in the objectives set
out at art 2 sub 1 of the said WID Act, which includes the identification of the ultimate
beneficial owner. R.5 deficiency 12 is sufficiently addressed.

May 31, 2017
R.5 (Deficiency 13): The requirement to terminate the business relationship and to
consider making a suspicious transaction report when identification of the customer
cannot be performed properly after the relationship has commenced.
56. At art 2a sub 4 if a service provider is no longer able to conduct client screening to the
satisfaction of art 2 of the WID after entering a business relationship, that service provider
is mandated to terminate that business relationship without delay. At art 2a sub 5 there is
the requirement for the making of a disclosure in these circumstances. R.5 deficiency 13 is
Recommendation 5 overall conclusion
57. Legislative action has resulted in Suriname significantly addressing 10 of the 13

deficiencies that were identified in the MER. Of the three outstanding deficiencies one
(deficiencies 2) is a minor deficiency, deficiency 3 is not sufficiently addressed and the
other, relating to statistics is addressed at R.32. The compliance with R. 5 up to a level
comparable at minimum to an LC.
Recommendation 10 PC
R.10 (Deficiency 1): There should be a requirement to keep all documents, which
record details of transactions carried out by the client in the course of an established
business relationship, and a requirement to keep all documents longer than 7 years
(if requested to do by a competent authority). R.10 (Deficiency 2): There should be a
requirement for financial institutions to ensure availability of records to competent
authorities in a timely manner.
58. Suriname has addressed both deficiencies through art 8 sub 1-2 of the WID. At sub 2,
service providers must maintain records in an accessible manner even after the statutory
retention period of seven (7) years, prescribed at sub 1, has expired. At sub 1 there is the
general requirement or the maintenance of records in an accessible manner for seven (7)
years after termination of the agreed business relationship. R.10 deficiency 1 and 2 are
59. Legislative action by Suriname has resulted in the two deficiencies being closed. The
compliance with R. 10 is up to a level comparable to C.
60. For Recommendation 13 the assessors had made seven (7) recommendations intended to
close the gaps they discerned in the MER. The deficiencies and related action, taken by
Suriname to address them are detailed below:

May 31, 2017
R.13 (Deficiency 1): The reporting obligation does not cover transactions related to
insider trading and market manipulation as these are not predicate offences for ML
61. As noted in the analysis of Surinames action taken to close Recommendation 1, insider
trading and market manipulation have been criminalized as predicates through the
enactment of the Act on Capital Markets (O.G. 2014 no 53). At art 1 (General Provisions),
of the said Act, insider trading is defined (art 1 sub (m)) whilst market manipulation is
defined at art 1 sub (n). Under art 34 (Penalty Provisions), both insider trading and market
manipulation are deemed to be criminal offenses and a person committing either is liable
to be sentenced to a maximum term of imprisonment of two years and to a maximum fine
of SRD 5 million. R1 deficiency 1 is sufficiently addressed. (The full analysis of
Recommendation 1 can be found here) R.13 deficiency 1 is sufficiently addressed.
R.13 (Deficiency 2): There is no requirement to report suspicious transactions

related to terrorist financing because the legislation on TF is not yet in place.
62. As noted in the analysis of Recommendation 1, Suriname criminalized terrorism by

enacting O.G. 2011 no 96, (art.1A. Art.1C (2) and the financing of terrorism by adding
paragraph k. Art 12 of the MOT ACT mandates any service provider that discover facts
indicating ML or TF, during the performance of their duties, to report such facts to the FIU.
(The full analysis of Recommendation 1 can be found here) R.13 deficiency 2 is
R.13 (Deficiency 3): Include in the State Decree on Unusual Transaction, the
requirement to also report attempted unusual transactions
63. In the SDUIT (S.B. 2003 No. 45), art 1 has been amended to mandate that a service
provider determine whether transactions, which are actually carried out or intended to be
carried out, are unusual in the context of the specific indicators annexed in the said State
Decree. Once such a determination is made the service provider is bound to report that
transaction or intended transaction in accordance with art. 12 of the MOT Act. Article 12
of the MOT Act is concerned with the reporting duty of service providers, to disclose
(report) to the FIU any facts they uncover which are indicative of ML of TF, whether or
not the related transaction was executed or intended to be executed. The combination effect
of the amended SDUIT and the amended MOT Act has the effect of completely addressing
the gap discerned by the Assessors. R.13 deficiency 3 is sufficiently addressed.
R.13 (Deficiency 4): The financial institutions that choose to use an UTR-interface for
reporting purposes, should be obliged to improve the quality of the UTRs as soon as
possible and in such a way that the disclosures contain all information as prescribed
by article 12.2. of the MOT Act.
64. This deficiency has been addressed through art 12 sub 2 of the MOT, which is concerned
with the Duty of Disclosure. In this regard art. 12 sub 2 a g has itemized the details
which service providers must provide when reporting suspicious transactions. R.13
deficiency 4 is sufficiently addressed.

May 31, 2017
R.13 (Deficiency 5): Consider whether the obligation to report unusual transactions
without delay is sustainable.
65. It has already been noted in the preceding paragraph that art. 12 of the MOT is concerned
with a Duty of Disclosure. At art. 12 sub 1 service providers are required to report UTRs,
to the FIU, immediately following the discovery of facts which point to money laundering
or terrorist financing. At art 22 of the MOT, which is concerned with Supervision, sub
1 a - c has entrusted several bodies with the responsibility of ensuring compliance with the
said MOT Act. In this regard, the CBS has been entrusted as the Supervisory Authority for
service providers; the Gaming Supervision and Control Institute as Supervisory Authority
in so far as gaming providers are concerned and the FIUS in so far as other non-financial
service providers are concerned. The Gaming Supervision and Control Institute was
created by article 2 of the act of July 2nd 2009 (O.G. 2009 no. 78). At art. 22 sub 2 the
supervisory authorities above can give directives to their respective supervisees for
facilitating compliance with the MOT Act. At art. 22 sub 3, where a service provider either
fails to comply with a directive by its supervisor or does not comply in a timely manner
that supervisor can impose a fine of up to 1 million Surinamese dollars for each
contravention. These provisions, once effectively implemented, can have the effect of
ensuring a high level of compliance by the supervisee stakeholders. R.13 deficiency 5 is
R.13 (Deficiency 6): the FIU and other competent authorities should make an
inventory to identify all financial institutions and DNFBPs that have a reporting
requirement, reach out to these parties and apply sanctions in case of non-compliance.
66. On November 7, 2012 Suriname forwarded a list of non-service providers in the

Jurisdiction to show that it already has an inventory in accordance with the Assessors
recommendation. This listing is regularly used by the FIUS in communicating with its
constituent supervisees. It is unclear whether the CBS and the Gaming Supervision and
Control Institute have done a similar inventory and whether all financial institutions and
DNFBPs in the Jurisdiction have now been identified. R.13 deficiency 6 is not as yet
R.13 (Deficiency 7): The FIU and other competent authorities should raise awareness
and enhance the sensitivity of all financial institutions and DNFBPs regarding ML
and TF.
67. This deficiency requires ongoing action to address it. Based on this, Suriname reported
having started conducting bi-monthly meetings between the FIUS and financial institutions
and DNFBPs.

May 31, 2017
68. Of the seven deficiencies, Suriname has sufficiently addressed 5, one has been significantly
addressed whilst the other is the subject of ongoing implementation. The compliance with
R. 13 is up to a level comparable at minimum to an LC.
Special Recommendation II - NC
SR. II (Deficiency 1): Besides the criminalization of FT, local authorities should see
to it, that, as soon as there is an act criminalizing the FT, comprehensive statistics be
kept on the number investigations, prosecutions and convictions for the act of FT.
69. This deficiency is identical to the 2nd deficiency 2 for Recommendation 1. Suriname
criminalized terrorism by enacting O.G. 2011 no 96, (art.1A. Art.1C (2)) and the
financing of terrorism by adding the paragraph k. The analysis of Recommendation 1 has
already detailed the legislative action which resulted in that deficiency being closed. (The
full analysis of Recommendation 1 can be found here) SR. II deficiency 1 is sufficiently
addressed.
Special Recommendation II overall conclusion
70. The lone deficiency has been sufficiently addressed through legislative action. The
compliance with SR. II is up to a level comparable at LC.
Special Recommendation IV - NC
71. SR. IV (Deficiency 1): There are no direct requirements for financial institutions to
report to the FIU when they suspect or have reasonable grounds to suspect that funds
are linked or related to, or to be used for terrorism, terrorist acts or by terrorist
organisations, regardless of the amount of the transaction and including attempted
transactions.
72. Art. 12 of the MOT is concerned with a Duty of Disclosure. At art. 12 sub 1 there is the
direct requirement whereby service providers are obligated to report UTRs, to the FIU,
immediately following the discovery of facts, with due observance of the indicators laid
down in the SDIUT, which point to money laundering or terrorist financing. This obligation
is applicable to transactions performed or those intended and thus incorporates attempted
transactions. SR. IV deficiency 1 is sufficiently addressed.
Special Recommendation IV overall conclusion
73. The lone deficiency for SR. IV has been sufficiently addressed through legislation which
mandates the reporting of UTRs whenever there is a suspicion that the facts surrounding
the transaction point to the financing of terrorism. The compliance with SR. IV is up to a
level comparable at minimum to an LC.

May 31, 2017
V. DETAILED ANALYSIS OF COMPLIANCE WITH THE KEY

RECOMMENDATIONS
Recommendation 3 - PC
74. The two shortcomings are the fact that the FT is not an offence under Surinamese laws,
and there are no statistics available to see how effective the legislation is in practice.
R. 3 (Deficiency 1): No legal basis for the confiscation of TF related assets, in the
absence of a TF offence.
75. In Suriname TF is now criminalised by virtue of art.1C (2) of O.G. 2011 no 96. Provisional
and confiscation measures related to TF are addressed, respectively in art. 82 and 82a of
the Criminal Proceeding Code, and in art. 50, 50a, 50b and 50c of the Penal Code as
amended in O.G. 2002 no. 67 thereby creating the legal basis for the confiscation of TF
related assets. R. 3 deficiency 1 is sufficiently addressed.
76. R. 3 (Deficiency 2): It is impossible to assess the effectiveness and efficiency of the
systems for combating ML, due to the lack of comprehensive and reliable (annual)
statistics with respect to property / objects seized and confiscated.
77. The maintenance and availability of comprehensive statistics are addressed at

Recommendation 32. (click here to read the text of Recommendation 32).
78. Of the two deficiencies noted for Recommendation 3, one has been sufficiently addressed
whilst the other which is related to the maintenance of statistics. The maintenance of
statistics is addressed at Recommendation 32. The compliance with R. 3 up to a level
comparable at minimum to an LC.
R.4 (Deficiency 1): the relevant competent authorities in Suriname be given the ability
to share locally and internationally, information they require to properly perform
their functions.
79. Art 9 of the MOT Act permits the FIUS to exchange data, held in its Register of
disclosures, with other FIUs which have similar functions as the said FIUS. Whilst the
Register of disclosures contains only information on UTRs, any exchange of this
information must be predicated on the establishment of a treaty, convention or MOU.
Within Suriname the data from the Register of disclosures can only be shared through the

May 31, 2017
Procurator General, and even so, only to investigation and prosecution authorities. At art
46 of the BCSSA, which came into force on 23rd November, 2011 the CBS has the authority
to provide data or information it obtained in the execution of its duties as a supervisor, to
a supervisory authority or any overseas authority charged with the supervision of other
financial markets, following the establishment of information exchange agreement
between the two (2) parties. There are several provisions before such information can be
shared. They include:
1. the provision of such information is not or is not expected within reason to be

in conflict with the interests purported to be protected under the BCSSA;
2. the CBS has ascertained the purpose for which the data or information is to be
used;
3. there are sufficient guarantees that the data or information will be used for no
purpose other than that for which they were intended, except where the CBSs
prior consent has been obtained for such use;
4. the confidentiality of the data or information is satisfactorily guaranteed;
5. the information and data provided by the CBS contain no names of individual
depositors of the relevant credit institution;
6. the data and information can be exchanged on the basis of reciprocity.
80. The provision at 5 above appears to be wholly restrictive and could have the effect of
limiting the sharing of specifics by the CBS. Suriname is required to demonstrate that the
implementation of that provision would not create an inhibition on the part of a competent
authoritys access to specific information it requires to properly carry out its AML/CFT
obligations.
81. The MOT Act is silent on the Gaming Supervision and Control Institute, as the other
supervisory authority in Suriname, ability to share information. However, Suriname has
reported that the necessary legislation to address this deficiency will be prepared. R.4
deficiency 1 is not sufficiently addressed.
82. The lone deficiency has not yet been sufficiently addressed.
Recommendation 23 - NC
R. 23 (Deficiency 1): Relevant supervisory authority has not been designated as

responsible for ensuring the compliance of their supervised financial institutions and
DNFBPs with AML/CFT requirements.
83. Art 22 of the MOT Act was enacted to specifically address this deficiency. In this regard,
the CBS has been entrusted as the Supervisory Authority for service providers; the Gaming

May 31, 2017
Supervision and Control Institute as Supervisory Authority in so far as gaming providers

are concerned and the FIUS in so far as other non-financial service providers are concerned.
In furtherance of this action and to demonstrate the implementation of these supervisory
measures by the CBS, Suriname reported that the CBS, in January of 2013, conducted
AML/CFT training for its Supervision Department, Financial Market Department and
Legal Department, in collaboration with the US Treasury department. In January 2013 as
well, the CBS created a manual for off-site and on-site examinations, to provide guidance
for guidance and direction to financial institutions examiners in conducting an AML/CFT
examination. That manual was designed to serve the user as a reference source describing
the fundamental procedures used to perform an AML/CFT off-site and on-site
examination. R.23 deficiency 1 is sufficiently addressed.
R. 23 (Deficiency 2): The money & value transfer companies, money exchange offices
and stock exchange are not subject to AML/CFT supervision and money transfer
offices and money exchange offices are not registered or licensed and appropriately
regulated.
84. At Chapter 2 of the MTOSA, art 3.1 has empowered the CBS with exclusive authority to
grant licences to legal entities wishing to carry on the business of a money transaction
office. Based on the definition ascribed to MTOs at art 1.b, a licence granted by the CBS
would allow a MTO to engage in either the exchange of currency or the transfer of
currency. However, Chapter 1 art 2 prohibits a licensee from engaging in both types of
transactions simultaneously. Chapter 2 art 5 details a number of requirements that a legal
entity must satisfy before a licence can be granted. At art 5.3 the CBS can refuse to grant
a licence if the Board of executive directors or board of supervisory directors or persons
holding a controlling interest was found guilty or is guilty of money laundering or is or was
involved in financial crimes. In similar circumstances, pursuant to art 10, the CBS can also
revoke a licence already granted. R. 23 deficiency is sufficiently addressed.
85. R. 23 (Deficiency 3): Surinamese authorities should consider regulating and

supervising the Stock exchange for AML/CFT purposes.
86. On May 21, 2014, Suriname enacted the Act on Capital markets as (O.G. 2014, no 53).
Art. 7 of this law places all market participants within the capital market under the
supervision of the CBS. At art. 10 the CBS is empowered to issue guidelines, for the
operational management of a stock brokerage firm or stock exchange, which includes
regulations regarding the combating of MF and TF. R. 23 deficiency 3 is sufficiently
addressed.
87. All three deficiencies have been sufficiently addressed through legislative action. The
compliance with R. 23 up to a level comparable at minimum to an LC.

May 31, 2017
R. 26 (Deficiency 1): That the missing implementing legal instruments be drafted

without further delay, so to consolidate the legal framework of the organisation and
functioning of the FIU
88. In May 2011, the Minister of Justice and Police issued a Ministerial Decree causing the
organisational chart of the Ministry of Justice to be changed to identify the FIUS as an
independent institute within the said ministry. Additionally, art 2 sub 1 of the MOT Act
has confirmed this action by establishing an office for disclosure of unusual transactions,
known as the Financial Intelligence Unit Suriname (FIUS) as an independent unit of the
Ministry of Justice and Police. R.26 deficiency 1 is sufficiently addressed.
R. 26 (Deficiency 2): To substantially increase the human and financial resourcing of
the FIU.
89. Suriname increased the strength of the FIUS by adding an additional eight (8) persons,
including four analysts and two lawyers, to the unit. Additionally, for fiscal year 2012, the
budget for the FIUS has been incorporated into the budget of the Ministry of Justice and
police. It is not clear how, incorporating the FIUS budget into the budget of the Ministry
of Justice and police, has redound to an increase in the financial resourcing of the FIUS.
Therefore, whilst the increase of the strength of the FIUS has demonstrably closed part of
this deficiency the other gap appears not to have been addressed. R. 26 deficiency 2 is not
R.26 (Deficiency 3): To move MOT to a location that ensures a secure conservation
and management of the sensitive information and the safety of the staff.
90. The FIUS was moved to a new location, situated in the business area of Paramaribo, in
September 2011. There the unit has been provided with additional office space and 24/7
security. R. 26 deficiency 3 is sufficiently addressed.
R. 26 (Deficiency 4): To improve the IT security measures to protect the sensitive and
confidential information.
91. In 2009, the FIUS reportedly acquired a server to store its information. Weekly backups of
the said information are also made. R. 26 deficiency 4 is sufficiently addressed.
R. 26 (Deficiency 5): That the sensitization and education of all reporting entities
should be substantially enhanced by awareness raising sessions and typology
feedback, aimed at an increased perception of suspicious activity to be reported.
92. Suriname reported that in 2009 the FIUS started conducting awareness seminars for
financial institutions and DNFBPs. Suriname has reported that part of these seminars
address issues regarding typologies which are reported by service providers and
documented in their UTR. By doing so the FIUS is providing typology feedback to service
providers with the aim to increase their perception of suspicious activities.
93. In June 2014, the FIUS launched its website (http://www.mot.sr ) where the FIUS annual
reports for the period 2003-2008; 2009; 2010; 2011; 2012; and 2013 are published and are

May 31, 2017
available for downloading. These reports include methods techniques and trends used in
ML, as identified by the FATF. The 2013 annual report is the last report available online.
A partially translated version of the 2012 report was sent to the Secretariat on April 29,
2014. That document showed detailed statistics on unusual transactions, covering the
period 2003 to 2010, with breakdowns on the value of such transactions particularized by
categories of reporting institutions. The translated document noted that typologies showing
the methods and techniques used for ML/TF and also related trends are included. Suriname
has also indicated that copies of the annual report are sent to the Ministers of Justice and
Police, Finance, the Attorney General, the Governor of the Central Bank, Embassies and
to all service provider. The annual report is made available to the general public and
students upon request. This additional information provided by Suriname shows that the
Jurisdictions FIU has been largely complying with the necessary elements of E.C. 26.8.
The closure of R.26 deficiency 5 is ongoing.
R. 26 (Deficiency 6): To issue the necessary guidance to the sector stressing the
importance of timely reporting, particularly of suspicious activity.
94. The FIUS issued guidelines, in October 2012, regarding reporting unusual transactions and
the identification obligations of service providers. At paragraph 3.2 of these guidelines a
reporting period of maximum 14 days for unusual transactions is prescribed for
transactions which fall under the scope of objective indicators whilst transactions falling
under the scope of a subjective indicator must be reported within five days. By prescribing
clear reporting timelines to be followed by reporting entities for the filing of UTRs,
Suriname has clearly demonstrated the importance for UTRs to be filed in a timely manner.
R.26 deficiency 6 is sufficiently addressed.
R. 26 (Deficiency 7): To increase the quality of the analytical process by systematically
querying all accessible sources, particularly the law enforcement and administrative
data (including tax information).
95. Art 7 sub 1 of the Mot Act authorises the FIUS to request information from government,
financial and non-financial institutions, if such information becomes necessary when
analysing UTRs. At art 7 sub 2 any government, financial and non-financial institutions
from whom the FIUS has requested information is obliged to comply. This legislative
action has created the basis upon which the FIUS can, on a case-by-case basis, access the
necessary information required to add value to its analytical process. R.26 deficiency 7 is
R.26 (Deficiency 8): To fully exploit all possibilities of information collection,
particularly by having the supervisory and State authorities report as provided by
the Law.
96. Based on the provisions of art 13 of the MOT, whereby government agencies must,
notwithstanding any confidentiality provisions that apply to them, inform the FIUS if they
discover, whilst carrying out their functions, any facts that point to ML of TF or the
suspicion thereof, the FIUS was expected to institutionalize a forum of supervisory
authorities and government agencies for collecting information on ML and FT. Suriname
has not conclusively reported this action. R.26 deficiency 8 is the subject of ongoing
implementation.

May 31, 2017
R. 26 (Deficiency 9): To intensify the efforts for the analysts to acquire better
knowledge and insight in money laundering techniques and schemes.
97. This deficiency is essentially related to the training and development of the staff of the
FIUS. Suriname has reported that this an ongoing effort which to date has seen orientation
visits to Belgium and participation in the Egmont Tactical Analysis Course in November
2009; a visit to the Netherlands Antilles in March 2010 and training in conjunction with
the USAs Treasury Department, in October 2012. R.26 deficiency 9 is the subject of
ongoing implementation.
98. Of the nine deficiencies identified by the Assessors, five have been sufficiently addressed
whilst the other three, which have been significantly addressed, are the subject of ongoing
implementation. The compliance with R. 26 is up to a level comparable at minimum to an
LC.
R. 35 (Deficiency 1): Suriname should take the necessary steps to fully and effectively
implement the Vienna and Palermo Conventions.
99. The Genesis of the Assessors comments can be found at paragraphs 620, 621 and 622 of
the MER. There are four issues articulated here, two of which are related to the Vienna
Convention and the other two (2) are related to the Palermo Convention. The resolution of
these issues are detailed below:
i. Issue#1 For Art 5 of the Vienna Convention and specifically related to R.28.2 (the
enforcement of foreign confiscation orders), the Assessors had recommended that
Legal certainty on the capability to execute foreign confiscation orders should be
ensured if necessary through specific legislation. Suriname enacted the WOTS Act
on October 25, 2016 and art 11 provides for the confiscation of objects, at the request
of a foreign state, pursuant to a treaty with Suriname. This sub-deficiency is
ii. Issue#2 - For Arts 15, 17 and 19 of the Vienna Convention is in relation to cross-border
cash transportation the WOTS Act is expected to address this issue. This sub-
deficiency is not yet addressed.
iii. Issue#3 and #4 which are in relation to Art 7 and 20 of the Palermo Convention and
are concerned with R.29, SR. IX and R.27.3. R.27.3 is an additional element whilst the
action taken by Suriname to close the deficiencies noted for R. 29 and SR. IX are
detailed in this report. This sub-deficiency is sufficiently addressed.
R. 35 (Deficiency 2): Suriname should forthwith initiate the accession procedure to

the CFT Convention and take the necessary implementation steps.

May 31, 2017
100. Per documents provided by Suriname, on July 18, 2013, the Jurisdiction acceded to the
United Nations International Convention for the Suppression of the Financing of
Terrorism. R.35 deficiency 2 is sufficiently addressed.
R. 35 (Deficiency 3): UN Res. 1267 and 1373 should be implemented fully and without
delay.
101. Suriname enacted the International Sanctions Act on May 21, 2014, (O.G.2014 no.54)
addressing the aspects of freezing of funds related to UN resolution 1267 and 1373. On
February 29, 2016, Suriname issued State Decree O.G. 2016 no 34, in order to implement
art 2 section 1 of the International Sanctions Act. Per art 2 of State Decree O.G. 2016 no
34, All balances and any other means belonging to Al-Qaeda, the Taliban and other
organizations associated natural persons or legal bodies, entities or bodies as referred to in
the Resolutions 1267, 1333, 1373, 1452, 1735, 1988, 1989, 2160, 2161 and 2170 have been
frozen. (The full analysis of the implementation of SR. III can be found here.) R. 35
102. Two of the three deficiencies for R.35 have been sufficiently addressed whilst the other
(deficiency 1) has been significantly improved through legislation. The compliance with
R. 35 is up from PC to a level comparable at minimum to an LC.
R.40 (Deficiency 1): The treaty condition should be discarded and replaced by the
generally accepted rule of information exchange with its counterparts, based on
reciprocity and the Egmont Principles of Information exchange. Ideally such
exchange should be allowed on an ad hoc basis or, if deemed necessary, on the basis
of a bilateral agreement between FIUs.
103. As noted at the analysis for R.26 in this report, art 9 of the MOT Act permits the FIUS to
exchange data, held in its Register of disclosures, with other FIUs, which have similar
functions as Surinames FIU. Such exchange must be predicated by the establishment of a
treaty, convention or MOU. R.40 deficiency is sufficiently addressed.
R.40 (Deficiency 2): The Law should expressly allow MOT to collect information
outside its register at the request of a counterpart FIU. One simple and adequate way
to realise this is to put such foreign request legally at par with a disclosure, which
would automatically bring them under the regime of art. 5 and 7 of the MOT Act.
104. Addressed through an amendment to art. 9 of the MOT Act. Specifically, through
O.G.2016 no.33 the FIU may now, apart from its own register, obtain information from

May 31, 2017
governmental, financial, and non-financial institutions, and also utilize other public sources
of information. R.40 deficiency 2 is not sufficiently addressed.
R. 40 (Deficiency 3): The confidentiality status of the exchanged information should

be expressly provided for to protect it from undue access or dissemination.
105. Suriname has reported that the conditions regarding the confidentiality status of the
exchanged information was included in the model MOU which has been prepared by the
FIUS. This model MOU was produced and at art 3 there is a restriction on the use of
information and documents being disseminated or to be used for administrative, judicial,
or prosecution purposes, without prior written consent. R. 40 deficiency 3 is sufficiently
addressed.
R.40 (Deficiency 4): The (physical) protection of the MOT data-base and its offices be
upgraded.
106. It has already been noted under the analysis of Surinames action relating to R. 26 that the
FIUS has been relocated to new secure accommodation within the business district of
Paramaribo and has reportedly acquired new server for securing its information. R.40
R.40 (Deficiency 5): The processing of TF related disclosures should be brought

within the assignment of the FIU as soon as possible, which would also increase the
chance of MOT acceding to the Egmont Group and its ESW.
107. Article III sub C and D of O.G. 2011 no 96 has amended the Act on the Disclosure of
Unusual Transactions (S.B. 2001 No. 65) giving effect to the assessors recommendation.
Consequently, the main task of the FIUS has been amended to include the compilation,
registration, processing and analysis of data important for the prevention and investigation
of money laundering, the financing of terrorism and other crimes. R. 40 deficiency 5 is
R.40 (Deficiency 6): A legal basis should be provided for information exchange
between the CBS and counterpart supervisors, by way of MOUs or otherwise.
108. As noted in the assessment of Surinames action relating to the deficiencies noted for R. 4,
the enactment of art 46 of the BCSSA has specifically closed this deficiency. R. 40
109. The six deficiencies for R. 40 have been addressed through legislative action bringing the
compliance with R. 40 up to a level comparable at minimum to an LC.

May 31, 2017
Special Recommendation I - NC
110. The deficiencies identified for SR. I and the recommended actions, made by the Assessors,
to close those deficiencies were identical to the deficiencies and recommended actions for
R. 35. Consequently, the analysis of the legislative action and other measures, taken by
Suriname, and detailed at R. 35 are also applicable here. (The full analysis of the R. 35 can
be found here).
Special Recommendation I overall conclusion
111. Two of the three deficiencies for SR.1 have been sufficiently addressed whilst the other
(deficiency 1) has been significantly improved through legislation. The compliance with
SR. 1is up from PC to a level comparable at minimum to an LC.
Special Recommendation III - NC
SR. III (Deficiency 1): No system in place complying with the relevant UN Resolution
and providing for an adequate freezing regime.
112. There are 15 essential criteria for SR. III, two of which are additional elements. Surinames
actions to close the deficiency are detailed below:
Freezing and where appropriate, seizing under the relevant U.N. Resolutions
113. III.1, III.2 & III.3 - The freezing of assets in accordance with S/RES/1267(1999) and
S/RES/1373(2001) is enabled through Art. 2 of the International Sanction Act (O.G. 2014
no 54) and State Decree O.G. 2016 no 34, which was enacted on February 29, 2016.
According to article 2 of State Decree O.G. 2016 no 34, All balances and any other
means belonging to Al-Qaeda, the Taliban and other organizations associated natural
persons or legal bodies, entities or bodies as referred to in the Resolutions 1267, 1333,
1373, 1452, 1735, 1988, 1989, 2160, 2161 and 2170 have been frozen. Means is defined
under article 1 of State Decree O.G. 2016 no 34 and encompasses funds as articulated in
the Terrorist Financing Convention.
114. The State Decree (O.G. 2016 no 131) has been enacted to give effect to, the actions
initiated under the freezing mechanism of other jurisdictions. A Council on International
Sanctions has also been established as a legal entity with responsibility for, among other
things, executing decisions sent to it by the Minister. Such decisions relate to
conventions or binding resolutions of international law organizations. According to art 4a
2 of State Decree O.G. 2016 no. 31, the Minister can also send such decisions to the other
entity(ies) responsible executing them. Whilst the Ministers of Justice and Police, Foreign
Affairs and Finance are responsible for the implementation of O.G. 2016 no. 31, the
Minister of Foreign Affairs is the recipient of the decisions related to Conventions,
pursuant to article 1 sub A 2 of the said O.G. 31.

May 31, 2017
115. III.4 (a) - Means referred to at article 2 of State Decree O.G. 2016 no 34, include means
which belong to the members or representatives of named organisations and also other
organisations which are associated with either natural or legal persons referred to in article
2. The reference at article 2 is to All balances and means and thus those means which are
wholly or jointly owned or controlled directly or indirectly by a third party or parties is
captured.
116. III.4 (b) - The definition of means clearly include interests, dividends or other income of
or value originating from or generated by assets.
117. III.5 Surinames communication strategy includes the publication, by the Council, within
five working days, in a digital way, of the freezing lists and of any amendments to these
lists and an announcement on the Councils website. This essential criterion however
requires Surinames financial sector and the general public to be informed immediately
upon Suriname such action.
118. III.6 - The Council has the responsibility for issuing guidelines to all service providers,
and supervising their compliance with the International Sanctions Act and its Amendments.
119. III.7 - The procedures for considering delisting requests and unfreezing of funds were laid
down by Ministerial Decree on October 25, 2016, as O.G. 2016 no. 133. Specifically, these
procedures can be found at parts I and J. At part I, any natural person or legal entity, entity
or body which appears on the sanction list of the UN, may submit a request for de-listing.
This request must include the reasons why the natural person or legal entity, entity or body
no longer meets the criteria for inclusion on the Sanctions List. A request for de-listing can
be addressed by the relevant natural or legal person, entity or body directly to the Office of
the Ombudsman, established by the UN Sanctions Committee or through the State in which
he resides, to be forwarded the Sanctions Committee of the UN. Regarding the timeliness
of delisting, the Council must notify the affected person or group, about the decision to
delist, within five working days, after the decision of the Minister of Foreign Affairs. At
part J, the Council is empowered to evaluate whether the grounds upon which the freezing
was based are still in force. All freezing measures are to be lifted by the Minister of Foreign
Affairs after having heard he Council. Regarding the timeliness of unfreezing action, a
copy of the Ministers decision is required to be forwarded to the Council immediately
following the Ministers decision and the Council in turn must inform the affected party
within five working days of that decision.
120. III.8 The procedures for unfreezing the funds or other assets of persons or entities
inadvertently affected by a Surinames freezing mechanism was laid down by Ministerial
Decree on October 25, 2016, as O.G. 2016 no. 133. Specifically, these procedures can be
found at part H, which is concerned with Mistaken Identity. Here, the Council has a
responsibility to investigate the identity and background of the affected person or entity
and inform the Minister of Foreign Affairs within two days of the completion of that
investigation. If the outcome of the investigation is for the freezing order to be lifted then
the Minister must make that order immediately.

May 31, 2017
121. III.9The Council is authorized to provide access to frozen funds for: payments of
necessary living expenses, medical treatment, the fulfillment of long-term financial
obligations or the payment of rent, utilities and insurance premiums; the payment of
reasonable professional fees and fees for receiving legal aid; and the payment of fees for
the preservation or maintenance of frozen funds or other resources. These noted expenses
are in accordance with S/RES/1452(2002). Access to frozen funds or resources is only
granted following the approval of the Minister for the performance of extraordinary
expenditure. If the Minister intends to grant such approval, he is required to make it known
to the UN sanctions committee. The Minister approves only with the expressed consent of
the UN sanctions committee.
122. III.10 - Any person who objects to a decision taken against him by the Council may object
in writing to the Council within 30 days after the decision is made known to that person.
Freezing, seizing and confiscation in other circumstances
123. III.11 Regarding whether means in the circumstances of art 2 of the International
Sanctions Act (O.G. 2014 no 54) and State Decree O.G. 2016 no 34 are subject to the
confiscations provisions relating to Recommendations 3.1 3.4, Suriname has advised that
whilst both the International Sanction act (O.G.2014 no 54), and the State Decree to
implement art 2 of the International Sanction act are aimed to create a legal freezing regime
procedures which will result in confiscation can only follow on the basis of evidence
presented during Penal Court hearings, resulting in confiscation orders according to art.54
E of the Penal Code (O.G. 2015 no.44). Suriname has promised to provide the Secretariat
with a translated copy of the O.G. 2015 no.44 as soon as it is available.
General provisions
124. III.12 Regarding whether there are laws and other measures which provide protection
for the rights of bona fide third parties, Suriname has stated that As general provision to
appeal against a seizing or confiscation order is laid down in article 460 of the Criminal
Preceding Code (O.G. 1977 no 94). Interested parties including bona fide third parties may
complain through a Court proceeding to withdraw a seizing or confiscation order. The
English translation of this provision was promised to the Secretariat.
125. III.13 The Minister has responsibility for supervising the activities of the Council which
is obligated to report its activities to the Minister. As for sanctions, the Council may impose
a penalty, not exceeding one million SRD per day, on any service provide which fails to
comply in a timely manner to the guidelines issued by the Council relating to freezing
decisions of the Minister.
Special Recommendation III overall conclusion
126. The mechanisms necessary to implement all the essential criteria, with the exception of III.
5, have been put in place by Suriname. The minor weakness here relate to the timeliness
with which the Council is required to inform the financial sector and the general public of

May 31, 2017
action taken under the Jurisdictions freezing regime. SR. III has been addressed to a level
of compliance comparable to a LC.
Special Recommendation V - NC
SR. V (Deficiency 1): The deficiencies established in respect of the criminalisation of

all designated predicate offences and terrorism financing should be remedied
forthwith. Also, the restrictive interpretation of the dual criminality principle should
be subject to reconsideration.
127. The Criminalization of all designated categories of offences was addressed at

Recommendation 1 (The full analysis of the R. 1 can be found here) 1 whilst the
deficiencies relating to extraditions will be fully addressed at Recommendation 37. (The
full analysis of R.37 can be found here).
Special Recommendation V overall conclusion
128. The lone deficiency has been addressed through legislative action. SR. V is assessed to
have been addressed to a level of compliance comparable to a LC.

May 31, 2017
VI. ANALYSIS OF MEASURES TAKEN IN RELATION TO OTHER

RECOMMENDATIONS RATED NC OR PC
129. Suriname has taken the following measures to address the other Recommendations that
were rated PC/NC. The information in this section is presented for information purposes
only and is not to be taken into consideration for Surinames application to exit the follow-
up process.
PREVENTIVE MEASURES - FINANCIAL INSTITUTIONS
Recommendations 14, 18 and 25 were all rated PC whilst Recommendations 6, 7, 8-11, &
17, 15, 19, 21, 22, 29, SR. VI and SR. VII were all rated NC.
130. For R. 14 the deficiency was related to tipping-off not being enforced through sanctions.
This gap was fully closed through the enactment of art 21 of the MOT, which is concerned
with Criminal Provisions. According to that article, violations of the rules laid down by the
MOT are criminal offences and punishable by a maximum prison sentence of ten years and
a maximum fine of SRD 5 million. Tipping-off is actually covered at art 25 of the MOT.
131. For R. 18 the Assessors had recommended that the Jurisdiction implement a specific
requirement that covers prohibition on the establishment or continued operation with shell
banks. Art 14 sub 1 of the MOT has specifically prohibited Suriname banks from entering
into or maintaining a correspondent banking relationship with a shell bank. Another
Assessors recommendation was for there to be specific enforceable obligations on financial
institution to reassure themselves that a respondent financial institution in a foreign country
does not permit its accounts to be used by shell banks. In this regard art 14 sub 2 of the
MOT has mandated that Suriname banks shall satisfy themselves that the financial service
providers that have their registered office outside of Suriname with which such Suriname
banks has either entered into or maintains a correspondent banking relationship, do not
permit their accounts to be used by shell banks. In addition to the above, directive II of
the CBS 2012 directives specifically prohibits financial institutions from entering into
correspondent relationships with so-called shell banks.
132. R. 25 deficiencies were related to the non-issuance of guidelines, and the provision of
appropriate feedback, by the FIU, to DNFBPs and FIs and DNFBPs respectively. These
deficiencies are identical to deficiency 5 and deficiency 6 at R. 26. The analysis of the
action taken by Suriname in this regard have been detailed under R. 26. Suriname has
sufficiently closed the noted gaps. (The full analysis of R.26 can be viewed here).
133. For R.6, Suriname achieved compliance with the PEP requirements through an amendment
to the WID Act which now has specific PEP-related AML/CDD provisions. At art 1 PEP
is defined as a person who occupies or has occupied an important public function abroad,
as well as his/her immediate family members and close associates. At art 4 sub b PEPs
are listed as one of the categories of customers for whom service providers are required to
perform more stringent client screening measures. At art 9sub 1 service providers are

May 31, 2017
required to establish policies and implement procedures which are aimed at determining
whether a client, potential client or beneficial owner is a PEP, and the source of assets of
any such clients. At art 9sub 2 any decision to enter a business relationship or perform an
individual transaction for a PEP can only be done or approved by the persons who has
overall management responsibility of the service provider. At art 9sub 3 if a client or
ultimate beneficial owner is determined to be a PEP subsequent to the establishment of the
business relationship then the business relationship can only be continued following the
receipt of approval to do so from the persons who has overall management responsibility
of the service provider. All of these obligations must be observed up to one year after the
client ceases to be a PEP.
134. Regarding R. 7, has Suriname has addressed the deficiency through art 13 of the WID.
Art 13 sub 1 a-c details the responsibilities of a banking institution in Suriname that is
planning to enter into a correspondent banking relationship. Payable-through accounts
and the need for financial institutions to be satisfied that the respondent has performed all
normal CDD obligations is specifically addressed at art 13 sub 1 c of the WID. Here
payable-through accounts are referred to as transit accounts and where a correspondent
banking relationship entails the use of such accounts, the Surinamese bank must satisfy
itself that the bank with which it has the correspondent banking relationship has identified
its clients that have direct access to those accounts. The CDD obligations for identification
and verification here must be in line with international standards and the Surinamese bank
must be certain that it is able to retrieve all relevant client identity data, from its respondent,
upon request. Art 13 sub 2 of the WID Act a banking institution is only permitted to enter
into a new correspondent banking relationship after receiving permission from the persons
charged with the overall management of the bank.
135. R. 8 deficiencies have been closed. Art 11 of the WID has addressed the recommendation
that financial institutions have adequate policies and procedures aimed at preventing the
use of new technologies to facilitate money laundering and terrorist financing particularly
with regards to business relationships and transactions involving clients who are not
physically present. Directive III of the CBS 2012 directives, which is concerned with
non-face to face business relationships or transactions has mandated that financial
institutions have policies and procedures in place to address any specific risks associated
with business relationships or transactions that do not involve personal contact.
136. As for R. 9, Suriname has addressed the deficiency through art. 2 of the WID. This article
permits service providers to rely on the client screening performed by a financial service
provider having its registered office in Suriname. Additionally, the CBS 2014 directives
have mandated that financial institutions satisfy themselves that the third party is regulated
and supervised for AML/CFT and has measures in place to comply with Surinames CDD
requirements. Finally, at Section IV of the 2016 AML/CFT Directives financial institutions
in these circumstances now have an obligation to immediately obtain from the third party
the necessary information concerning certain elements of the CDD.

May 31, 2017
137. R. 11 deficiencies have been addressed through art 10 sub 1 a & b of the WID. However,
though the WID is silent on the obligations with regards to large transactions, this is
covered at Directive VI of the CBSs 2012 directives.
138. For R.17 Suriname has closed the deficiencies through art 21 and 22 of the MOT. Art. 21
has created criminal offences punishable by a maximum prison sentence of ten years and
a maximum fine of SRD 5 million for violations of the rules laid down by the MOT. Art.
22 authorises the supervisors to impose a maximum fine of SRD 1 million for each
contravention by a service provider that does not comply, or does not comply on time, with
the obligations laid down in the directives which the said supervisor has issued. At art 56
of the BCSSA, the CBS is authorized to impose a financial penalty on a credit institution
for non-compliance, including non-compliance with guidelines issued under art 16. The
amount of all such penalties are set by order or decree, on the understanding that the penalty
payable per infringement may not exceed SRD 1,000,000 and under no circumstances can
such penalty exceed 25 percent of the annual profit. Finally, at art. 1B of the Act
Penalization of Legal Entities of September 5, 2002, provision is made for penalizing
criminal acts perpetrated by legal persons. Here punishments and other measures may be
imposed on the legal person itself or against those persons who ordered the crime, as well
as against those persons who were actually in charge of the prohibited act.
139. Regarding R.15, directive X paragraphs a-e of the 2012 directives has subsumed all of the
deficiencies with the exception of the requirement that the internal audit function be
adequately resourced. On April 1, 2015, the CBS issued amended directives. Directive XL
is concerned with compliance and internal audit. Here, internal audit departments are
required to be robust in order to carry out their tasks. There are minimum requirements
which direct that the head of the department should possess knowledge and management
qualities; employees should be sufficiently trained and the internal audit department must
have sufficient employees at its disposal. Further, if the internal audit department is not
sufficiently equipped for its functions the Executive Board is required to ensure that this is
reversed within the short term.
140. For R. 19, no action has been taken by Suriname.
141. R.21 is partially addressed. The Assessors had recommended that Suriname should issue a
law or regulation to implement the requirements of this Recommendation. At art 4 f of the
MOT service providers are mandated to perform a more stringent client screening prior to
the business relationship or transaction and during the business relationship if the natural
persons or legal entities originate in countries or jurisdictions that do not meet at all or
sufficiently the internationally accepted standards in the field of AML/CFT. At art 10 sub
2 of the WID transactions involving jurisdictions which do not sufficiently meet all the
internationally accepted standards in AML/CFT are required to be the subject of an
investigation into the background and object of that transaction and the findings are to be
recorded and kept for seven years. In the action taken by Suriname the legislation appears
to be deficient in the requirement for effective measures to be in place to ensure that
financial institutions are advised of concerns about weaknesses in the AML/CFT systems
of other countries. Another apparent deficiency is the lack of an ability/requirement to

May 31, 2017
apply counter measures on countries which do not appropriately apply the FATF
Recommendations.
142. R. 22 three deficiencies have been addressed through CBS 2012 Directives. At directive
XI, FIs are required to ensure that the provisions of the said directives are applied in their
branches and subsidiaries in Suriname and abroad and where there are differences in the
standard of supervision between the home country and the host country, FIs are required
to apply the higher of the two (2) but subject to the provisions of the local regulations.
Additionally, if a foreign countrys regulations make it impossible for a FI to comply with
the CBS directives that FI must report this to the CBS.
143. R. 29 has been addressed owing to the CBS being given the general power to compel
production or to obtain access to all records, documents or information relevant to
monitoring compliance. According to art 29 sub 1 a of the BCSSA, in order to carry out
its supervision functions, the CBS is entitled, at all times, to have unrestricted access to all
accounts, records, documents and other data of a credit institution. This entitlement exists
irrespective of who has possession of the information noted above. In the new art 22 of the
MOT Act the CBS has been appointed as the AML supervisory authority of financial
service providers. Under this article the CBS is authorized to give directives to the service
providers that fall under its supervision for the purpose of facilitating compliance with the
MOT Act.
144. Regarding SR. VI, all the deficiencies were addressed by Suriname. As noted for the
analysis of deficiency #2, at R.23 of this report, art 3.1 has empowered the CBS with
exclusive authority to grant licences to legal entities wishing to carry on the business of a
MTO. The 2012 directives covered MTOs and Suriname reported having already
conducted two (2) onsite inspections for MTOs, which were done in collaboration with the
OTA. Suriname reported on April 29, 2014, that the Financial Markets Division of the CBS
maintains a list of MTC agents and Sub-agents. A copy of this list was provided to the
Secretariat on May 14, 2014. The CBS can impose sanctions against credit institutions for
failure to comply with the AML/CFT guidelines issued pursuant to art. 16 of the BCSSA.
145. Regarding SR. VII, there was one recommended action aimed at covering several
deficiencies. The 2016 directives has addressed many of the deficiencies however
weaknesses still exists. Specifically, under Electronic Transfer of Funds, at page 9 of the
2016 AML/CFT Directives, the FI which will execute any cross-border wire transfer higher
than USD/EUR 1,000 has a responsibility to request and record the originators name;
account number; and address or national identity number, or customer identification
number, or date and place of birth. There is no obligation for the ordering financial
institution to identify and verify the identity of the originator per the standards anticipated
at Recommendation 5. Also, Suriname has not provided any information regarding the
record keeping requirements where technical limitations prevent the full originator
information accompanying a cross-border wire transfer from being transmitted with a
related domestic wire transfer.

May 31, 2017
PREVENTIVE MEASURES DESIGNATED NON-FINANCIAL BUSINESSES

AND PROFESSIONS
Recommendations 20 was rated PC whilst Recommendations 12, 16 and 24 were all rated
NC.
146. All the deficiencies noted for R.20 are now closed. Real estate agents and car dealers have
been brought under the scope of the ID law. Likewise, pursuant to the art. 1, paragraph d,
and 12 of the MOT Act real estate agents and car dealers are subject to the reporting
obligation of the MOT Act. The CBS has launched a modernization project which will
result in electronic clearing and settlement. There is also the Banking Network Suriname
(BNETS), which was founded in 2005, and which aims to promote electronic payment and
integrating payment between FI. Finally here, the Jurisdiction has reported that both
transactions through ATM and POS have increased annually. The BNETS statistics
provided on April 29, 2014, shows that since 2007 to 2013, the use of debit cards has
doubled while payments via POS increased by almost six times.
147. Suriname has closed all the deficiencies, for R. 12, but one, which relates to continuous
and effective guidance to DNFBPs, on the purpose of, and compliance with the ID law. It
is noted however that the WID makes no distinction between DNFNPs and the other FIs in
Suriname therefore the positive influence of the new legislative measures on
Recommendations 5, 6, 8-11 have cascaded onto R. 12.
148. For R.16, the steps taken by the Jurisdiction towards closing the gaps for R.13-15 have
already been noted in this report. It is important to note here as well that even though art
22 of the MOT mandates the Gaming Supervision and Control Institute, in so far as gaming
providers are involved, to issue directives (guidance), none have as yet been issued.
149. Regarding R.24, at Art 22 1 b of the MOT the Gaming Supervision and Control Institute
has been made the supervisory authority, charged with supervising compliance with the
provisions of MOT Act, particularly as they relate to gaming providers. The Gaming
Supervision and Control Institute, as supervisory authority, is authorized to give directives
to the gaming providers and impose a penalty for non-compliance with such directives.
Law on Hazard Games (Wet op de Hazardspelen) regulates the licensing of casinos in the
Jurisdiction. However, this law was dated and contained no AML/CFT provisions.
LEGAL SYSTEMS & RELATED INSTITUTIONAL MATTERS
Recommendation 27 was rated PC while Special Recommendation IX was rated NC.
150. For R.27 the deficiency noted by the Assessors were inherently related to implementation
issues specific to the relation between the financial investigative team (FOT) and the FIUS
regarding financial investigations and the use of UTRs. Suriname has reported that in 2012
training has been provided to members of the FOT in Suriname and that same year two
members of the FOT attended financial investigations training in France. It is unclear how
the action taken by Suriname positively affected the implementation of R. 27.

May 31, 2017
151. There was one deficiency for SR. IX and the Assessors had recommended that the
Suriname authorities should decide on the choice between a disclosure or a declaration
system for cross-border transportation of currency or bearer negotiable instruments and put
in place such system aimed at discovering criminal or terrorist related assets without delay.
Suriname has reported introducing a border management system (BMS) in July 2012.
This BMS reportedly will register incoming and outgoing passengers and address threats
in the area of terrorism, illegal trade, drugs trafficking and illegal trafficking of immigrants.
To complement the BMS, on January 22, 2015, the Minister of Finance decided that a
declaration system be commenced from January 30, 2015. A copy of the declaration form
actually being used was forwarded to the Secretariat on April 21, 2016.
LEGAL PERSONS AND ARRANGEMENTS & NON-PROFIT ORGANISATIONS
Recommendation 33 and Special Recommendation VIII were rated NC.
152. Suriname closed the deficiencies for R. 33 by amending the Surinamese Commercial Code
(O.G. 2016 No. 103) to abolish the issuance of new bearer shares and create an opportunity
for existing bearer shares to be converted to registered shares. This addresses the Assessors
recommendation for measures to be taken to prevent bearer shares from misuse for ML.
153. SR. VIII was rated NC and the Assessors noted a Complete absence of an adequate
legislative and regulatory system for the prevention of misuse of the non-profit sector by
terrorists or for terrorism purposes The MER at paragraph 611
(Suriname_3rd_Round_MER) had noted that There were no specific laws and regulations
with regards to NPOs To cure this deficiency, the Assessors had recommended that
Suriname Should see to it that laws are passed and other targeted measures taken to avoid
the misuse of NPOs for FT. On February 29, 2016, Act (O.G. 2016 no. 32) was enacted,
and brought into force on March 3, 2016, to amend the WID Act. This law is directly
related to the CDD obligations applicable in higher risk situations and was intended to
make enhanced customer due diligence mandatory for Surinames non- profit
organizations. In essence however, O.G. 2016 no. 32 has added transactions done by non-
profit organizations prior to the business relationship or transaction done during the
business relationship, to the list of situations, found at article 4 of the said WID Act, for
which service providers in Suriname are bound to conduct more stringent client screening
(enhanced due diligence) measures. These obligations are burdens placed on service
providers and are in no way applicable to the non-profit organizations themselves.
154. Inherently, none of the essential criteria for this SR has been met. SR. VIII is bounded by
the principles that countries would review their domestic non-profit sector with a view to:
ensuring that the existing laws are adequate; that pertinent information relating to the make-
up of the sector is available. There should also be an outreach to the sector and an oversight
regime put in place to raise awareness on TF risks and promote transparency. Here targeted
record keeping to ensure certain types of records are available to the public and the ability
to impose sanctions are required, as is the need to ensure that Surinamese NPOs are either
licensed or registered. These are just some of the obligations noted in the Interpretive Notes

May 31, 2017
and Best Practices Paper for SR. VIII. Surinames approach would not redound to any of
these measures being implemented because the stringent measures prescribed at article 4
of the WID are limited to customer due diligence to be carried out by the service providers.
This Special Recommendation is open.
NATIONAL AND INTERNATIONAL COOPERATION
Recommendation 37 and 38 were rated PC.
155. The two deficiencies for R. 37 and R. 38 were identical. Suriname has addressed the first
deficiency by criminalizing the missing designated categories of offences. (See R.1).
Regarding the other deficiency, for a person to be extradited from Suriname there must
first be the presumption that the person to be extradited is guilty and the offence upon
which guilt is presumed must carry a term of imprisonment of one year or longer in both
Suriname and the requesting State. A person can also be extradited where they have served
at least four months imprisonment for a similar offence to which his extradition is being
requested. Finally, there must be a similar offence in Suriname and the person to be
extradited must have also breached that offence in Suriname. Suriname has provided
information, which shows statistics on requests for persons to be extradited from Suriname.
All such requests were granted based on court decisions. Suriname further advised the
Secretariat, on November 3, 2014, that the comments by the Assessors were made without
looking into the extradition law and since in practice no problems occur with the execution
of foreign MLAT's requests, there is no need to change the law.
OTHER ISSUES
Recommendation 30 was rated PC while Recommendation 32 was rated PC.
156. Regarding R. 30, the staff of the FIU was increased to twelve persons and the budget for
2012 has been incorporated into the budget of the Ministry of Justice and Police. There
was the appointment of a senior prosecutor, within the Office of the Attorney General, to
provide instructions and guidance in the investigation of ML/TF cases; on October 1, 2012
the CBS recruited 40 trainees from the University to be employed within various
departments of the said CBS, including the supervisions department. After an initial six (6)
months orientation period (ending in March 2013) these employees were expected to be
assigned to the different supervisory sections of the CBS and trained accordingly.
Suriname, with the assistance of the U.S. Treasury Department Office of Technical
Assistance, has conducted two (2) onsite inspections of the credit institutions in April and
July of 2013. The inspection itself involved five (5) staff members from the CBS and
covered five (5) days onsite plus several days in preparation and post examination analysis
of gathered information and preparation of a report. This process has had the effect of
improving Surinames technical capacity to conduct future onsite inspections.
157. For R. 32, Suriname has reported having completed and distributed a template designed to
keep comprehensive statistics on the number of investigations, prosecutions, convictions

May 31, 2017
and mutual legal assistance. This template has been distributed to the FIU, FOT, Gaming
Board Prosecutors Office and the CBS.

May 31, 2017
ANNEX 1 SUSPICIOUS TRANSACTION REPORTS AND OTHER REPORTS
Table 2: STRs received by the FIUS
REPORTING INSTITUTIONS 2015 2016

Banking Institution 286162 146530
Life Insurance Companies 1
Exchange Offices 1427 3826
Money Transfer Companies 306 2319
Notaries 356 1395
Dealers in Motor Vehicles 89 16
TOTAL 288341 154086
Table 3: ML/TF Cases Analyzed and Reported by the FIUS
2015 2016
1a NUMBER OF ML/TF CASES 9 13
ANALYZED
1b NUMBER OF ML/TF CASES 3 1
REPORTED

May 31, 2017
ANNEX II ML & FT INVESTIGATIONS; PROSECUTIONS AND CONVICTIONS
Law enforcement
2016
1. 10
a. Number of ML/TF cases investigated
b. Number of perpetrators in investigated ML/TF cases 23
Prosecution
2016
2. 3
a. Number of ML/TF cases prosecuted
b. 5
Number of perpetrators prosecuted ML/TF cases
Penal court decision - 2016
3. 1
a. Number of ML/TF cases prosecuted ending in a conviction
2
b. Number of perpetrators prosecuted in ML/TF cases ending with a
conviction
4. What was the total amount of confiscated funds by court order $34.000
5. How many suspicious transaction reports resulted in investigation, 0

prosecution or convictions for ML, FT or an underlying predicate
offence

May 31, 2017
ANNEX III MUTUAL LEGAL ASSISTANCE OR OTHER INTERNATIONAL

REQUESTS FOR CO-OPERATION
a. Requests received from the FOT
2016
7
a. Number of mutual legal assistance and extradition requests (including 12
requests relating to freezing, seizing and confiscation) that are made or
received, relating to ML, the predicate offences and FT
2016
b. The nature of the requests for legal assistance ML
2016
c. Number of granted requests 12
2016
d. Number of refused requests 0
e. Reasons for refusing N/A
f. The time required to respond on, or execute a request for legal 3 months
assistance

May 31, 2017
b. Requests relating to the Prosecutor General
Incoming requests
Requesting State MLA Commission Extradition Total

Rogatory
Netherlands 68 20 7 95
Brazil 2 - - 2
Curacao 1 - - 1
Belgium 1 - - 1
Poland 1 - - 1
Sweden 1 - - 1
Venezuela 2 - - 2
French Guyana 1 - - 1
Total 77 20 7 104
Outgoing Requests
Requested state MLA Commission Extradition Total

Rogatory
Netherlands 6 - - 6
Guyana 2 - - 2
French Guyana 1 - - 1
The Bahamas 1 - - 1
Total 10 - - 10

May 31, 2017
ANNEX IV OTHER ACTION
AML/CFT on-site and off-site inspections conducted by the supervision department of FIU
Suriname.
2014 2015 2016

1 Number of on-site inspections 2 6 4
2 Number of off-site inspections 0 0 2
AML/CFT on-site off-site inspections conducted by the Bank Supervision department of the
Central Bank of Suriname.
2013 2014 2015 2016

1 Number of on-site 3 6 6 6
inspections
In 2014 the Financial Market Department conducted 9 on-site inspections at money transfer offices.

May 31, 2017
ANNEX V TRAINING
CBS
Since 2013 several staff of the Central Bank has participated in AML/CFT training e.g.
- In 2014 Technical Assistance from US Treasury Department
- Anti- Money Laundering Examination Seminar, Federal Reserve System, British Virgin
Islands
- Caribbean Financial Action Task Force Assessors Training, CFATF, Trinidad and Tobago

Matrix
Report and Submission to CFATF for Removal from Follow-up Process
Suriname (May 2017)
Forty Rating Recommended Action Action Undertaken Remaining Action to be taken

Recommendations
Legal systems
1. ML offence PC i. It is recommended that i. Closed 6th FuR
legislation is adopted to
make insider trading and CBS is drafting legislation
market manipulation and regarding the supervision of the
terrorism and the financing capital market. In this legislation
of the same offences under insider trading and market
Surinamese laws. manipulation will be
criminalized. According to the
Suriname ICRG/CFATF Action
Plan 2012 this legislation should
come into force before the end of
this year.
i
Central Bank working group is
discussing draft legislation with
stakeholders. The draft was
prepared in collaboration with
CARTAC. The stakeholder for this
May 31, 2017
activity is the Suriname Stock

Exchange Board who requests the
bank to review certain parts of the
draft. Discussions will result in
finalizing this draft in the very near
future.
The draft Act on Capital Markets

has been approved by the Council
of Ministers and was forwarded to
ii. Besides the criminalization the State Advisory Council. Their
of FT, local authorities comments have been forwarded to
should see to it, that, as the ministry of Finance to be
soon as there is an act implemented in the draft. Insider
criminalizing the FT, trading and market manipulation
comprehensive statistics will be covered by this act.
be kept on the number
investigations, The Act on Capital markets came
prosecutions and into effect on May21th2014 (O.G.
convictions for the act of 2014, no 53). The Act defines
FT insider trading in art 1 sub m as:
knowledge of specific inside
information which has a direct or
indirect bearing on a securities-
issuing institution whose securities
are traded on the stock exchange
for which the holder has been
granted a license, or which pertains
to trading in such securities,

May 31, 2017
- where such information has

not been brought into the public
domain,
- the disclosure of such
information would impact
significantly on the price of the
securities or on the price of
securities deriving therefrom.
Market manipulation is defined in
art 1 sub n as follows:
- transactions or trade orders
which give incorrect or misleading
signals or are likely to do so in
relation to the supply of securities,
the demand for securities or the
price of same, or where one or
more persons act in concert to
maintain the price of a security at
an abnormal or artificial level,
- transactions or trade orders
which rely on the use of improper
schemes or any other form of fraud
or deception;
- the dissemination of
information through the media,
including the Internet, or through
other channels, which provides
incorrect or misleading signals or
is likely to do so in relation to

May 31, 2017
securities, including the

dissemination of false rumors and
false or misleading reports in
respect of which the person who
disseminated the information knew
or must have known that said
information was incorrect or
misleading.
According to art 19 of this Act it
is prohibited for any person who
has inside in
formation to make use of said
inside information for ones own
benefit or for the benefit of third
parties in order to acquire, dispose
of, or to attempt to acquire or
dispose of, directly or indirectly,
the securities relating to this inside
information
According to art 21 it is prohibited
for any person to become involved
in market manipulation. Stock
brokerage firms and stock
Exchanges should put structural
arrangements in place in order to
prevent and to expose market
manipulation.
Both Market Manipulation and
Insider Trading are deemed to be

May 31, 2017
criminal offences under the Capital

Market Act and punishable with
jail sentences and fines.
The Act penalizing Terrorism and
the Financing of Terrorism (O.G.
2011 no. 96) (CFT legislation)
came into force on July 30, 2011.
In the legislation also amendments
were made regarding the Fire arms
Act (art. II) and the Act regarding
suspicious transactions (MOT Act
art. III). In general all categories of
predicate offences, related to
money laundering are applicable to
the financing of terrorism (art. I C
sub art. 71a). That also includes
acts in preparation of activities
related to terrorism.
ii.
A template to keep comprehensive
statistics on the number of
investigations, prosecutions and
convictions is developed and will
be formally distributed in August
2012 to the stakeholders: FIU,
Prosecutors office and the Central
Bank. This is in line with the

May 31, 2017

Plan 2012.
ii.
Templates to keep comprehensive
investigations, prosecutions,
convictions and mutual legal
assistance has been developed and
formally distributed to the
stakeholders: FIU, Financial
Investigative Team (FOT),
Gaming Board, Prosecutors office
and the Central Bank.
2. ML offence LC i. Besides the criminalization A template to keep comprehensive Closed 4th FuR
mental element of FT, local authorities statistics on the number of
and corporate should see to it, that, as investigations, prosecutions and
liability soon as there is an act convictions is developed and will
criminalizing the FT, be formally distributed in August
comprehensive statistics 2012 to the stakeholders: FIU,
be kept on the number Prosecutors office and the Central
investigations, Bank. This is in line with the
prosecutions and Suriname ICRG/CFATF Action
convictions for the act of Plan for 2012.
FT

May 31, 2017

Investigative Team (FOT), it
3. Confiscation PC i. The two shortcomings are Terrorism has been penalized in Closed 4th FuR
and provisional the fact that the FT is no art. I A of the Act dated July 29,
measures offence under Surinamese 2011 (O.G. 2011 no. 96). The
laws, and there are no financing of terrorism is penalized
statistics available to see in art. IC of the same Act, in which
how effective the art.71a was added to the Penal
legislation is in practice. Code.
Provisional and confiscation
measures also related to TF are
addressed, respectively in art. 82

May 31, 2017
and 82a of the Criminal Proceeding

Code, and in art. 50, 50a, 50b and
50c of the Penal Code as amended
in O.G. 2002 no. 67.
A template to keep comprehensive
investigations, prosecutions and
Prosecutors office and the Central.
This is in line with the Suriname
ICRG/CFATF Action Plan for
2012.

Investigative Team (FOT),

May 31, 2017
Preventive measures
4. Secrecy laws PC i. The assessment team Article 9 of the MOT Act is revised Legislation to be prepared with
consistent with recommends that the in order to make sharing of regard to the sharing of
the relevant competent information possible, both, locally information by the FIU and the
Recommendatio and internationally. In line with the Gaming Board with other
authorities in Suriname be
ns Suriname ICRG/CFATF Action supervisory authorities.
given the ability to share
Plan for 2012, this legislation was
locally and internationally,
adopted by Parliament on the 17th
information they require to of July 2012 and entered into force
properly perform their on the 9th of August 2012.
functions.
Art 9 addresses the aspect of
sharing of information for
investigation and prosecution
purposes. Art 13 will be revised in
order to allow MOT to share
information with other supervisory
authorities i.e. the Central Bank and
the Gaming Board
The draft MOT Act with

amendments regarding sharing of
information has been sent to the
Council of Ministers for advice

May 31, 2017
Draft Act to incorporate NPOs in

both the MOT and WID act has
been finalized in order to forward to
the Council of Ministers.
The Banking and Credit System

Supervision Act, which entered
into force on November 23rd 2011,
gives the CBS the authority to
enter into information exchange
agreements (MOUs) with
supervisory authorities abroad
(art. 46).
Based on the Banking and Credit

System Supervision Act of 2011,
the CBS entered into an
information exchange agreement
(MOU) with the Caribbean Group
of Banking Supervisors in July
2012.
Legislation amending art.13 of the

MOT Act (O.G. 2016 no 33),
allowing MOT to share
information with other supervisory

May 31, 2017
authorities i.e. the Central Bank

and the Gaming Board, was
of February 2016 and entered into
force on the 3rd of March 2016.
See attachment: Disclosure of
Unusual Transactions Act (MOT
Act), under D. art.13 section 2.
Art. 13 section 1 of the MOT Act

(O.G.2012 no.133) already states
that authorities that are entrusted
with the supervision of financial
and non-financial institutions as
well as government agencies must,
notwithstanding any
confidentiality provisions that
apply to them, inform the FIUS if
they discover facts during the
performance of their duties that
point to money laundering,
financing of terrorism or that give
rise to a reasonable suspicion
thereof.

May 31, 2017
Legislation amending art.I of the

WID Act (O.G. 2016 no. 32),
requires non profit organizations
to perform enhanced customer due
diligence when receiving,
supplying, subsidizing, collecting
and transferring financial means,
was adopted by Parliament on the
29th of February 2016 and entered
into force on the 3rd of March
2016.
See attachment: Act on the
Identification Requirements for
Service Providers (WID Act), art.I)
5. Customer due NC Suriname should implement By amending the WID Act and the Closed 4th FuR
diligence the following elements from MOT Act, Suriname has
Recommendation 5 which implemented the following
have not been fully elements from Recommendation
addressed: 5. In line with the Suriname
2012, legislation regarding the
following elements was adopted
by Parliament on the 17th of July
2012 and entered into force on the
9th of August 2012.

May 31, 2017
i. All financial institutions i.

should be fully and The CBS has issued in April 2012,
effectively brought under new AML/CTF regulations for the
AML and CFT regulation financial sector. These new
and especially under the regulations are in line with the
broad range of customer recommendations of the MER with
due diligence regard to: Comprehensive CDD
requirements; requirements, Peps, cross border
correspondent banking, none face
to face transactions, KYC
regarding third parties and
beneficiaries, recordkeeping,
enhanced due diligence on high
risk and complex transactions.
ii.
Legislation amending the MOT
Act and the WID Act, art. 1, in
ii. The definition of financial order to bring the definition of
activities should be financial activities in accordance
updated in accordance with with the FATF Methodology was
the definition of financial adopted by Parliament.
activities in the FATF
Methodology;
iii.
In legislation amending the WID
Act, ART. I sub B amendments are
made to art. 2, requiring CDD
measures when carrying out wire

May 31, 2017
iii. Financial institutions transfers for occasional

should be required to transactions.
undertake full CDD
measures when carrying
out occasional transactions
that are wire transfers in
circumstances covered by iv.
the Interpretative Note to In legislation amending the WID
SR VII or occasional Act, ART. I sub F and G
transactions above the amendments are made to art. 4 and
applicable threshold of 6, in order to update previously
USD/EUR 15.000; obtained CDD information and to
keep it relevant.
iv. The requirement to

undertake CDD measures v.
in cases where there is a In legislation amending the WID
suspicion of terrorist Act, ART. I sub E a new art. 3a is
financing and in cases added, regarding CDD measures
where there are doubts for Suriname and foreign legal
about the veracity or persons.
adequacy of previously
obtained customer
identification data;
vi.
v. The requirement to verify Act, ART. I sub G provisions has
the legal status of legal been included regarding the
arrangements like trusts

May 31, 2017
and understand who is identification requirements of the

(are) the natural person(s) beneficial owner for legal persons.
that ultimately owns or
control the customer or vii.
exercise(s) effective
control over a legal In legislation amending the WID
arrangement such as a Act, ART. I sub D amendments are
trust; made to art. 3, with the obligation
to obtain information regarding the
purpose and nature of the business
vi. The requirements relation.
regarding identification
and verification of the viii.
beneficial owner for legal In legislation amending the WID
persons, including the
Act, ART. I sub G amendments are
obligation to determine the made to art. 6, in order to update
natural persons who previously obtained CDD
ultimately own or control
information and to keep it relevant.
the legal person;
ix.
vii. The obligation to obtain In legislation amending the WID
information on the purpose Act, ART. I sub F amendments are
and intended nature of the made to art. 4 for enhanced due
business relationship; diligence on higher risk categories
of customers, business relations and
transactions.
x.

May 31, 2017

Act, ART. I sub K adds a new art.
10 requiring special attention
viii. No specific requirement to regarding business relations and
perform ongoing due transactions with natural and legal
diligence on business persons from countries or territories
relationships; with none or less compliance with
international recommended
AML/CFT requirements.
xi.
ix. Performing enhanced due Act, ART. I sub F and G
diligence on higher risk amendments are made to art. 4 and
categories of customers, 6, in order to apply CDD measures
business relationships or to existing clients on the basis of the
transactions; business relationship or nature and
higher risks of transactions to be
conducted.
xii.
x. There should be some In legislation amending the WID
consideration/assessment Act, ART. I sub C adds a new
made based on which there article 2a section 3 and 4,
is a satisfaction about prohibiting a transaction to be
compliance with the conducted if identification and
Recommendations by verification of the client pose
countries which are

May 31, 2017
currently seen as compliant difficulties and as a last resort the

without any doubt; business relation can be terminated.
xiii.
xi. There are no general Act, ART. I sub C adds a new
requirements to apply article 2a section 4 which requires
CDD measures to existing termination of the business
customers on the basis of relationship. Accordingly the
materiality and risk; business relation will be
terminated.
xii. When regulating the

identification and
verification of beneficial
owners, a requirement to
stop the financial
institution from opening an
account, commence
business relations or
performing transactions
when it is unable to
identify the beneficial
owner satisfactorily.

May 31, 2017
xiii. The requirement to

terminate the business
relationship and to
consider making a
suspicious transaction
report when identification
of the customer cannot be
performed properly after
the relationship has
commenced.
6. Politically NC Legislation to amend article 1, art. Closed 3th FuR
i. Suriname should
exposed persons 4 and art. 9 of the WID act, in order
implement the necessary
to include AML/CDD measures
requirements pertaining to
PEPs. regarding PEPs was adopted by
Parliament, on the 17th of July
9th of August 2012.
The CBS has issued in April 2012,
new AML/CTF regulations for the
financial sector in line with the
recommendations of the MER with
regard to comprehensive CDD
requirements for Peps.

May 31, 2017
According to the Explanatory

Notes of the Act on the
Service Providers the term
important public functions
includes head of States, prominent
politicians, high-ranking officials,
court officers or senior officers,
directors of state enterprises,
important political party officials.
Business relationships with family
members or partners of Peps harm
the reputation in the same way as
with these Peps itself. Persons in
the middle or lower part of the afore
mentioned categories do not fall
under this definition.
7. Correspondent NC Legislation to amend article 1, 4, Closed 3th FuR

i. With regard to
banking 13 and 14 of the WID act,
correspondent banking,
introducing legal requirements
financial institutions
applicable to correspondent
should be required to
banking relationship was adopted
determine that the
by Parliament, on the 17th of July
respondent institutions
AML/CFT controls are
9th of August 2012.
adequate and effective, and
regarding payable through

May 31, 2017
accounts, to be satisfied The CBS has issued in April 2012,

that the respondent has new AML/CTF regulations for the
performed all normal CDD financial sector in line with the
obligations. recommendations of the MER with
regard to comprehensive CDD
requirements related to cross border
correspondent banking.
8. New NC Legislation amending article 11 of Closed 3th FuR

Suriname should also
technologies & the WID act, which require
implement the necessary
non face-to-face financial institutions to pay special
requirements pertaining non-
business attention to ML/TF threats that can
face to face business
arise from new or developing
relationships or (ongoing)
technologies and to have policies
transactions.
and procedures in place to address
In addition, steps should be specific risks associated with non-
taken to ensure that financial face to face business relations or
institutions have policies in transactions was adopted by
place or take such measures as Parliament, on the 17th of July
may be needed to prevent the 2012 and entered into force on the
misuse of technological 9th of August 2012.
developments in ML or TF These non-face to face businesses
schemes. are also addressed by the new CBS
AML/CFT regulations for the
financial sector and are among
others: internet banking, phone
banking, POS payments, reloadable
or account-linked value cards.

May 31, 2017
9. Third parties Closed 10th FuR

NC i. If financial institutions are Legislation amending article 12 of
and introducers permitted to rely on third the WID act, permitting financial
institutions to rely on the client
parties or introducers the
Surinamese legislation screening performed by another
needs to be adjusted financial service provider having
accordingly. If financial its registered office in Suriname
institutions are not with regard to a client introduced
permitted to rely on third by this financial service provider,
parties or introducers for was adopted by Parliament, on the
th
17 of July 2012 and entered into
some elements of the CDD th
process, the law or force on the 9 of August 2012.
regulation should specify According to this new legislation
this the ultimate responsibility for
customer identification and
verification remains with the
financial institution which relies on
the introducer.
new AML/CTF regulations in line
with the recommendations of the
MER which contain criteria for
financial institutions who rely on
intermediaries.
According to the CBS AML/CFT
Directive of April 2012 financial

May 31, 2017
service providers established in

Suriname may act as intermediaries
as long as they meet the applicable
conditions. The ultimate
responsibility for customer
identification and verification
remains with the institution.
Article 12 of the Act on the

Service Providers stipulates that
upon request of a service provider
all data and information of the
client screening will be provided by
the third party and that all
information will be made available
without delay.
The amended CBS AML/CFT
Directive came into force as of
April 1, 2015. Section IV states that
financial institutions are permitted
to make use of an intermediary for
the implementation of CDD-
procedures or in order to introduce
new customers. A financial service
provider established in Suriname
may act as an intermediary, so long

May 31, 2017
as they meet the applicable

conditions. The ultimate
responsibility for customer
identification and verification
remains with the financial
institution.
No reference is made since the 6th
follow up report. We are of the
opinion that this recommendation is
closed.
The CBS AML/CFT Directive has
been amended on October 13, 2016.
Under Section IV of amended
directive it is included that if
financial institutions rely on
intermediaries or other third parties
to perform some of the elements of
the CDD process, then the
following criteria should be met.
- Financial institutions
relying upon a third party should be
required to immediately obtain
from the third party the necessary
information concerning certain
elements of the CDD process
(transaction based);

May 31, 2017
should be required to take adequate
steps to satisfy themselves that
copies of identification data and
other relevant documentation
relating to CDD requirements will
be made available from the
intermediary upon request without
delay (relationship based);
should be required to satisfy
themselves that the third party is
regulated and supervised, and has
measures in place to comply with
the CDD requirements;
- The intermediary should be
originated from countries that
adequately apply the FATF
Recommendations.
10. Record keeping PC i. Closed 4th FuR

i. There should be a
requirement to keep all In this regard article 8 of the ID law
documents, which record requires all service providers to
details of transactions keep all documents, which record
carried out by the client in details of transactions carried out

May 31, 2017
the course of an by the client in the course of an

established business established business relationship,
relationship, and a longer than 7 years (if requested to
requirement to keep all do by an competent authority).
documents longer than 7 ii.
years (if requested to do by
an competent authority). Legislation amendingarticle 8 of
the WID Act, in order to make it
possible to continue recordkeeping
of details regarding transactions
which has been carried out by a
client, for a period longer than 7
years, once requested by a
competent authority was adopted
ii. There should be a 2012 and entered into force on the
requirement for financial 9th of August 2012.
institutions to ensure
availability of records to
competent authorities in a
timely manner.
11. Unusual NC i. There should be a i. Closed 3th FuR
transactions requirement for financial Article 10 of the WID Act was
institutions to pay special
amended. Financial institutions are
attention to all complex, now required to pay special
unusual large transactions,
attention to all complex, unusual
or unusual patterns of large transactions and all unusual
transactions, that have no patterns of transactions which have

May 31, 2017
apparent or visible no apparent economic or feasible

economic or lawful lawful purpose.
purpose. The background and purpose of
such transactions should be
examined, the findings should be
established in writing and be
available for competent authorities
for seven years. Upon request of a
competent authority, the findings
should be available for a longer
period.
In line with the Suriname
2012, this new legislation was
of July 2012 and entered into force
on the 9th of August 2012.
ii.
ii. There should be financial sector in line with the
requirement for financial recommendations of the MER with
institutions to examine as regard to the aspects of complex,
far as possible the unusual large transactions or
background and purpose of unusual patterns of transactions that
the transaction and to set have no apparent or visible
forth the findings in economic or lawful purpose.
writing and to keep these

May 31, 2017
findings available for

competent authorities and
auditors for at least five
years.
12. DNFBP R.5, NC In line with the Suriname Closed 3th FuR
Suriname should modify the
6, 8-11 ICRG/CFATF Action Plan for
ID law in order for it to cover
the full range of CDD 2012, Suriname has modified the
measures as set out in the ID law to cover the full range of
FATF standards CDD measures as set out in the
FATF standards. This legislation
17th of July 2012 and entered into
force on the 9th of August 2012.
In this regard, the following
elements are implemented in the ID
law.
Suriname should introduce in A new article 22 has been added to

the ID law or in another law the MOT Act, regarding
provisions regarding the supervision of the DNFBPs,
supervision of the DNFBPs on respectively the Gaming Board for
their compliance with the the casinos and lotteries and MOT
identification requirements of to supervise the other DNFBPs as
the ID law. In doing so mentioned in the Act.
Suriname should set out the

May 31, 2017
supervisory instruments and

powers, and designate a public
entity or government agency
tasked with the actual The new art. 22 of the MOT Act
supervision of DNFBPs. enables the supervisory authorities
to impose administrative sanctions
Suriname should introduce in once a service provider does not
the ID law or in another law comply with the obligations
provisions enabling effective, pursuant to the law.
proportionate and dissuasive
sanctioning of non-compliance The supervisory authorities will
by DNFBPs with their deposit the collected fines and
obligations pursuant to the ID collection costs in the treasury.
law. More specifically
Suriname should consider the
introduction of administrative FIU has started awareness raising
sanctioning of violations of the sessions for all service providers
ID-law by DNFBPs next to the since 2009, andthwill continue doing
existing general criminal this. On the 28 of February 2012
sanctioning provision of article an awareness raising session for
10 of the ID law. In doing so financial and non-financial service
Suriname should also providers and all other stakeholders
designate a public entity or was held in collaboration with the
government agency tasked CFATF.
with the imposition of the Awareness raising sessions for 7
administrative sanctions on Categories of DNFBPs including
non-compliant DNFBPs. casinos, real estate agencies,
notaries public, jewelers, car
dealers, administration offices and

May 31, 2017
Suriname should provide accountancy firms were organized

proper, continuous and by the FIU in November 2012.
effective guidance to the During these sessions also the
DNFBPs on the purpose and reporting aspects according to the
compliance with the ID law, in AML/CFT Guidelines of October
order to raise their awareness 2012 were addressed.
of their obligations and FIU will continue its awareness
responsibilities under the ID raising sessions for the non-
law and to facilitate and financial service providers during
enhance their compliance. 2013.
In these sessions issues related to
The ID law should contain AML/CFT guidelines and the
more specific provisions for completion of UTRs will also be
the identification of the addressed. It is expected that 2
ultimate beneficiary owners training sessions will be held
involved in transactions before August 2013.
carried out by DNFBPs. In April 2013 the first training
DNFBPs should also be sessions for all financial and non-
required to understand the financial service providers (a total
ownership and control of 153 participants) were held and
structure of the customers, and the second training session is
to determine who are the planned for November 2013
natural persons that ultimately whereby approximately 450
own or control the customer. participants will be invited. The
training sessions will be held
annually. For 2014 a semi-annual
training program is scheduled.

May 31, 2017
In the WID Act a new art. 3a has

been added regarding special CDD
measures relating to local and
foreign legal persons, public
corporations and religious
organizations.
Article 4, first section, of the
ID law, which deals with Legislation to require identity
identification of natural establishment of a natural person
persons acting on behalf of a acting on behalf of another when
customer, requiring DNFBPs providing a service as meant in
in the process to establish the paragraph d of article 1 of the ID
identity of such a natural law was adopted by Parliament.
person prior to the provision of The ID law was modified, art. 1 sub
a financial service, should be q, art 2 and art. 2a, so as to inquire
modified so as to requiring about ownership and control
identity establishment of a structure of the customers, and to
natural person acting on behalf determine who the natural persons
of another when providing a are that ultimately own or control
service as meant in paragraph the customer.
d of article 1 of the ID law.
Article 7, second section, of
The ID law, art. 4, was modified,
the ID law should be expanded
so as to require identity
to require other DNFBPs
establishment of a natural person
besides currently civil notaries,
acting on behalf of another for all
accountants and lawyers, to
record the transaction amount

May 31, 2017
as part of the identification services provided, financial and

requirements pursuant to non-financial.
article 7 and 3 of the ID law.
Suriname should improve its
registration system for legal
persons, especially for
foundations, in order to better
enable DNFBPs to better
comply with their
identification obligations
under the ID law. Additionally,
measures, including legal
ones, should be taken to better
enable DNFBPs to identify the
ultimate beneficiary owner
through the legal persons
registration system.
Suriname should consider
bringing the scope of the ID
requirements for casinos, real
estate agents, dealers in
precious metals, dealers in
precious stones, lawyers, civil
notaries, accountants and other
DNFBPs in accordance with
essential criterion 12.1. This
means introducing a monetary
threshold for casinos, dealers

May 31, 2017
in precious metals and dealers

in precious stones, as well as a
description of activities for real
estate agents, lawyers, civil
notaries, accountants and other
legal professionals, for
activities subject to the
identification requirements.
Suriname should fully
implement the Law on
lawyers. In doing so, Suriname
might consider to have an
order decree pursuant to article
34 of this law enacted with
provisions on the identification
of clients by lawyers, thereby
further strengthening the
identification framework for
lawyers. Suriname may also
consider introducing similar
provisions for other
professionals such as civil
notaries and accountants.
13. Suspicious NC The reporting obligation under Criminalization of insider trading Closed 6th FuR
transaction the MOT Act should cover and market manipulation in the
reporting transactions related to insider capital Market Act will qualify

May 31, 2017
trading and market these offenses as predicate offences

manipulation. with the obligation to report these
The reporting duty needs to be offences to the FIU.
explicitly in the law to include In the State Decree on Unusual
all funds where there are Transaction (SDIUT) all services
reasonable grounds to suspect regarding securities transactions are
or they are suspected to be listed in Annex A. Institutions need
linked or related to, or to be to determine whether a conducted
used for terrorism, for terrorist or intended transaction is unusual
acts, or by terrorist within the meaning of the law when
organizations or those who rendering these services. Art 12 of
finance terrorism. the MOT ACT requires that service
providers that discover facts during
the performance of their duties
which point to money laundering
and financing of terrorism are
obligated, with due observance of
the indicators laid down by SDIUT
to immediately disclose an effected
or intended unusual transaction in
writing -digitally or non-digitally-
to the FIU.
The State Decree on Indicators of
Unusual Transactions (SDIUT) has
The assessment team advises to
been approved (O.G.2013 no.148)
include in the State Decree on
and entered into force on August
Unusual Transactions the
15th, 2013.
requirement to also report

May 31, 2017
attempted unusual
transactions Based on art. III sub C of the CFT
legislation (OG 2011 no. 96)
The financial institutions that UTRs are filed with the FIU
choose to use an UTR-interface regarding transactions, which are
for reporting purposes, should suspected to be related to
be obliged to improve the terrorism, terrorist acts of terrorist
quality of the UTRs as soon as organizations. Art 12 MOT Act
possible and in such a way that already incorporates attempted
the disclosures contain all unusual transactions.
information as prescribed by Sub 1 of art. 12 was amended in
article 12.2. of the MOT Act. order to include UTRs based on
TF (Art. III of the Terrorist Act
(O.G. 2011 no. 96).
The authorities should
consider whether the
obligation to report unusual Art. 12 of the MOT Act, explicitly
transactions without delay is requires reporting of all unusual
sustainable. transactions or attempted unusual
transactions.
Sub 2 of art. 12, where the

reporting requirements are
stipulated was amended, obligating

May 31, 2017
The FIU and other competent financial institutions to improve

authorities should make an the quality of the UTRs.
inventory to identify all
financial institutions and
DNFBPs that have a reporting
requirement, reach out to these Enforcement of the obligation to
parties and apply sanctions in report transactions without delay is
case of non-compliance. supervised by the authorities
mentioned in art. 22 of the MOT
Act.
In the legislation amending the

MOT Act art. 22 has been added
The FIU and other competent
which gives the FIU the supervision
authorities should raise
over the DNFBPs. In this article
awareness and enhance the
sanctions are applied in case of
sensitivity of all financial
non-compliance. This legislation
institutions and DNFBPs
regarding money laundering
and terrorist financing risks.
FIU continues with awareness

raising session for all service
providers and will continue these
sessions in 2014. During these

May 31, 2017
sessions ML/FT typologies will be

shared with the service providers.
14. Protection & no Closed 3th FuR

PC Violation of the prohibition Art 22 and 23 of the Mot Act
tipping-off against tipping-off should be include sanctions in case of
tipping-off.
enforced by sanctions.
Legislation amending art. 25 of the
MOT Act, which prohibits
disclosure of data and information
given or received in relation to the
MOT Act, including data related to
UTRs as mentioned in art. 12 sub
1 was adopted by Parliament, on
the 17th of July 2012 and entered
into force on the 9th of August
2012.
Violation of this prohibition is
sanctioned in art. 21 of the MOT
Act
The new AML/CTF regulations of

the CBS also address the aspects of
protection and no tipping off.

May 31, 2017
15. Internal NC i. The Surinamese The CBS has issued in April 2012, Closed 8th FuR
controls, authorities need to new AML/CTF regulations for
compliance ensure that financial institutions in line with
&audit Recommendation 15 in the recommendations of the MER
all its aspects is clearly with regard to the internal control,
required by law, compliance and audit. The
regulation or other regulations introduce a formal
enforceable means all requirement for the financial sector
of which requirements to appoint a compliance officer,
should be capable of who will be responsible for the
being sanctioned. design and implementation of the
compliance policy.
Specific directive from the Central

Bank for the financial service
providers regarding internal audit
is pending. It is expected to come
in effect by the end of 2014.
Amended CBS AML/CFT
regulations have been discussed
with the Bankers Association and
will come in effect on April 1st
2015.
Under the amended regulations
(paragraph 11 sub e) financial
service providers will be required

May 31, 2017
to have an adequately resourced

internal audit department. The
regulation sets minimum
requirements for the department.
April 1, 2015.
(paragraph 11 sub e) financial
service providers are required to
have an adequately resourced
internal audit department. The
regulation sets minimum
requirements for the department.
See attached AML/CFT
Directive, April 1, 2015
16. DNFBP R.13- NC Art 12 sub 1 of the MOT Act was The Gaming Board has
Suriname should address the
15 & 21 amended in order to include UTRs presented its action plan which
deficiencies and shortcomings
based on TF (Art. III of the includes matters related to
noted in sections 2.5 and 3.7
Terrorist Act (O.G. 2011 no. 96). their operations of which
regarding the functioning of
Reporting by DNFBPs of ML/TF supervision is part of.
the FIU and the application
is based on art. 12 sub 1 of the
and enforcement of the
MOT Act.
provisions of the MOT Act and
the Decree Indicators Unusual

May 31, 2017
Transactions, since these are Art. 22 sub 1c of the MOT Act

equally applicable to the gives the FIU the supervision over
DNFBPs. These include, but is DNFBPs. Art 22 sub 2 gives FIU
not limited to, DNFBPs should the authority to introduce
also be required to understand AML/CFT guidelines.
the ownership and control
structure of the customers, and Art. 22 sub 3 and sub 4 introduces
to determine who are the administrative sanctions.
natural persons that ultimately Art. 1 sub d of the MOT Act has
own or control the customer been amended in order to include a
the introduction of adequate wide range of services performed
compliance supervision by DNFBPs.
provisions in the MOT Act and
the introduction of effective, In line with the Suriname
proportionate and dissuasive ICRG/CFATF Action Plan for
sanctions in the MOT Act. The 2012, this legislation was adopted
latter could be done by by Parliament on the 17th of July
introducing administrative 2012 and entered into force on the
sanctions in the MOT Act. 9th of August 2012.
More specifically, Suriname
should provide adequate and
continuous guidance to the
DNFBPs in order to reach and
maintain satisfactory
compliance with the MOT Act
and the Decree Indicators
Unusual Transactions. This
guidance should have as one of

May 31, 2017
its primary objectives the

prompt and continuous
reporting of transactions based
on the subjective indicators as
well as transactions based on
the objective indicators.

Suriname should bring the
definitions of services by
lawyers, civil notaries and The October 2012 MOT Guidelines
other legal professionals in the for all service providers also
MOT Act and Decree addresses the gaming providers.
Indicators Unusual Additional guidelines related to the
Transactions in line with the operations of the gaming providers
circumstances set out in will be introduced at a later stage.
essential criterion 16.1 of the
Methodology. While doing so
Suriname should also take the
legal professional secrecy of
lawyers and civil notaries into
account.
Suriname should consider
lowering the threshold
amounts mentioned in the
relevant objective indicators in
order to better reflect the
current realities of the

May 31, 2017
Surinamese financial-
economic situation, thereby
increasing the amount of
reports to be received pursuant
to these indicators.
It should be noted that a
significant amount of
subjective indicators described
in the various categories are
very broad and actually do not
relate with the typical activities
pursued by the relevant
DNFBPs. For example, the
subjective indicators for legal
professionals cover various
services which are typically
financial services but are not
services provided by legal
professionals. Reference can
be made to sections 7 up to and
including 11 of the subjective
indicators for legal
professionals (category F of
article 3 of the Decree
Indicators Unusual
Transactions). Suriname
should address this issue in
order to ensure effective

May 31, 2017
reporting based on the

subjective indicators.
17. Sanctions NC i. The assessment team i. Closed 6th FuR
recommends to include Art. 21 and 22 of the MOT Act
administrative (e.g. include a wide range of penal and
fines) or civil sanctions administrative sanctions to deal
in the AML/CFT with natural and legal persons
framework, which are mentioned as service providers in
in practise easier the act, that fail to comply with
enforceable and in AML/CFT requirements.
practice more effective
than penal provisions. In line with the Suriname
2012, this legislation was adopted
9th of August 2012.
ii.
Based on art. 16 of the Banking
ii. The range of sanctions and Credit system Supervision Act
should be broadened (O.G. 2011 no. 155), the CBS has
with administrative the authority to issue AML/CFT
sanctions for financial regulations for financial
institutions, DNFBPs, institutions.
for directors and senior
Art. 56 of the Banking and Credit
management of
system Supervision Act, enables
financial institutions,

May 31, 2017
to include the more the CBS to impose fines for

direct possibility to bar breaches of AML/CTF regulations.
persons from the Based on art. 11 sub 1h of the
sector, to be able to Banking and Credit system
more broadly replace Supervision Act the CBS will be
or restrict the powers of able to revoke a license of a
managers, directors, or financial institution for violations
controlling owners for of AML/CTF regulations.
AML& CFT breaches.
In addition, there
should be the According to art. 17 of the
possibility to restrict or Banking and Credit System
revoke a license for Supervision Act, the CBS has the
AML and CFT authority to place the credit
violations. institution under undisclosed
custody. This may happen when
the CBS is of the opinion that the
credit institution neglects to act on
a directive of the CBS including
AML/CFT guidelines. The CBS
may appoint a person upon whose
instructions the credit institution
must perform their tasks,
according to the directives of the
CBS.
In the new article 22 of the MOT
Act the CBS has been appointed as
the AML supervisory authority of

May 31, 2017
financial service providers. Under

this article the CBS is authorized to
give directives to the service
providers that fall under its
supervision for the purpose of
facilitating compliance with the
MOT Act. This article also enables
the supervisory authority i.c the
CBS to impose a maximum fine of
SRD 1 million for each
contravention on a service provider
that does not comply, or does not
comply on time, with the
obligations laid down in the
aforementioned directives of the
CBS.
According to article 1B of the Act
Penalization of Legal Entities of
September 5, 2002, regarding
detailed amendments to the
criminal code in connection with
the adoption of general provisions
on the criminal liability of legal
persons, sanctions for AML/CFT
violations can be applied to
directors, senior management and
financial institutions.

May 31, 2017
18. Shell banks PC i. Suriname should i. Closed 3th FuR

review its laws, Legislation amending the WID Act,
regulations, and art. 1 and 14, prohibits financial
procedures and institutions to enter into a
implement a specific correspondent bank relation or to
requirement that establish relations with shell banks.
covers in a formal way, In line with the Suriname
the prohibition on the ICRG/CFATF Action Plan for
establishment or 2012, this legislation was adopted
continued operation by Parliament on the 17th of July
with shell banks. 2012 and entered into force on the
9th of August 2012.
ii.
Based on art. 14 sub.2of the WID
Act financial institutions should
also ensure that their foreign
ii. There should a specific correspondent relations do not have
enforceable obligation accounts with, or facilitate shell
on financial banks.
institutions to reassure
themselves that a The CBS has issued in April 2012,

May 31, 2017
respondent financial financial sector in line with the

institution in a foreign recommendations of the MER with
country does not regard to prohibiting financial
permit its accounts to institutions to have correspondent
be used by shell banks. bank relationships with shell banks.
19. Other forms of NC i. Suriname should

reporting consider the feasibility
and utility of
implementing a system
where financial
institutions report all
transactions in currency
above a fixed threshold
to a national central
agency with
computerized database.
20. Other NFBP & PC i. Suriname is urged to i. Closed 6th FuR
secure correct the deficiencies
transaction discussed in sections The National AML commission
techniques 4.1 and 4.2 of this has reviewed the State Decree on
report which are also Indicators of Unusual Transactions
present with respect to including the transaction amounts
the real estate agents that are required for all financial
and car dealers. and non - financial services. The
draft SDIUT was sent to the
council of Ministers for approval

May 31, 2017
ii. Suriname should and will be forwarded to the State

require the transaction Advisory Council for advice.
amounts to be
established as well
when real estate agents The State Decree on Indicators of
and car dealers Unusual Transactions (SDIUT) has
establish the identity of been approved (O.G.2013 no.148)
a client pursuant to the and entered into force on August
ID law. 15th, 2013.
iii. Suriname should also

consider lowering the The Central Bank has lounged a
threshold amounts project regarding the
mentioned in Decree modernisation of the payment
Indicators Unusual system, which will result in
Transactions in order electronic clearing and settlement.
to improve the amounts This will encourage the
of reports received development and use of modern
based on the objective and secure techniques for
indicators. conducting financial transactions.
iv. As Suriname has a

largely cash-based Banking Network Suriname N.V.
economy with a fairly (BNETS) was founded in February
large informal 2005 with the aim of promoting
component it is electronic payments and
encouraged to integrating payments between
introduce measures for financial institutions operating in
the development and Suriname as well as integrating

May 31, 2017
use of modern and payments with foreign financial

secure techniques for institutions. BNETS has the
conducting financial following key activities:
transactions that are - Counseling, support and
less vulnerable to encourage collective cashless
money laundering payment services that contribute to
an innovative, high-quality, secure
and efficient electronic payment
system in Suriname;
- Integration of payments between
financial institutions operating in
Suriname and abroad;
- Encouraging the awareness
regarding the electronic payments
in Suriname.
Both transactions through ATM

and POS have increased annually.
Statistics indicates that since 2007
to 2013 the use of debit cards has
doubled while payments via POS
increased by almost six times
21. Special NC i. Suriname should Legislation amending the WID

attention for issue a law or Act, art. 4 and 10, introducing legal
higher risk regulation to requirements to pay special
countries attention to transactions with
implement the
persons and institutions from high

May 31, 2017
requirements of risk countries, was adopted by

Recommendatio Parliament, on the 17th of July 2012
n 21. and entered into force on the 9th of
August 2012.

recommendations of the MER with
regard to transactions with
countries that are considered to be
high risk.
According to art 12 sub 1 of the

MOT act (as amended in august
2012 O.G. 2012 no 133) a new
State Decree dated 2 July 2013
O.G. 2013 no 148 has been issued.
Annex A of this State Decree
stipulates a reporting obligation
regarding transactions with (legal)
persons who are established in
countries or jurisdictions which
have been designated by the
Minister of Justice and Police and
the Minister of Finance as countries
or jurisdictions that do not or do not
sufficiently meet the internationally

May 31, 2017
accepted standards in the field of

the prevention and the fight against
money laundering and terrorist
financing.
Draft act to amend art.4f and 10 of

the WID act regarding special
attention to high risk countries has
been prepared and will be
forwarded to the Council of
Ministers
Amended CBS AML/CFT

2015.
In paragraph 7 financial service
providers are required to report to
the FIU transactions with (legal)
persons in countries or jurisdictions
that have been designated as high
risk.
April 1, 2015.

May 31, 2017

(paragraph VII) financial service
providers are required to report to
the FIU transactions of (legal-)
persons established in countries or
jurisdictions which have been
designated by the Minister of
Justice and Police and the Minister
of Finance as being countries or
jurisdictions which do not comply,
or do not comply sufficiently, with
common international standards in
the sphere of the prevention and
combating of money laundering
and the financing of terrorism.
Information concerning countries
with an increased risk can be
obtained (amongst other places)
from: Mutual Evaluation Reports
and the public statements of
FATF/CFATF, FSAP reports of
the IMF and the World Bank and
the website of the Central Bank of
Suriname.

May 31, 2017
22. Foreign NC 1) There should be a In accordance with art. 16 of the Closed 3th FuR
branches binding obligation on all Bank and Credit System
&subsidiaries financial institutions:
Supervision Act, the Central Bank
i. To pay particular has issued AML/CTF regulations
attention to the principle that address the requirement for
with respect of countries credit institutions to ascertain that
which do not or said regulations also apply to their
insufficiently apply foreign branches and subsidiaries.
FATF If standards of the foreign country
Recommendations; are higher, the highest standard
ii. Where the minimum should apply, notwithstanding the
requirements of the home country.
AML/CFT
requirements of home
and host country differ
to apply the higher
standard to the extent
that host country laws
permit;
iii. To inform the home
country supervisor
when a foreign branch
or subsidiary is unable
to observe appropriate
AML/CFT measures.

May 31, 2017
23. Regulation, NC i. A relevant supervisory I Closed 6th FuR

supervision and authority should be
monitoring Legislation which introduces a new
designated as art 22 of the MOT Act gives
responsible for ensuring supervisory authority to:
the compliance of their
supervised financial a. CBS for the financial sector
institutions and b. The Gaming Board for the
DNFBPs with gaming industry
AML/CFT
requirements. c. FIU for all other DNFBPs
9th of August 2012.
I
In January 2013 CBS in
collaboration with the US Treasury
Department conducted a AML/CFT
training for its Supervision
Department, Financial Market
Department and Legal Department.

May 31, 2017
The CBS is now working on a

AML/CFT onsite examination
manual.
For 2013 three AML/CFT on-site

inspections of credit institutions are
scheduled of which two has been
conducted in April and July 2013
with assistance of the U.S. Treasury
Department, Office of Technical
Assistance. The inspection itself
involved five staff members plus
the advisor and covered 5 days
onsite plus a number of days in
preparation and post examination
analysis of gathered information
and preparation of a report.
Ii
Under the Act concerning the
supervision of Money Transaction
ii. There should be a Offices the CBS is the sole
licensing authority for Money
general requirement for
money transfer offices Transfer Offices and Money
Exchange Offices.
and money exchange
offices to be licensed or
registered. In addition,

May 31, 2017
money transfer offices With assistance of the US Treasury

and money exchange Department a special AML/CFT
offices should also be onsite examination manual for
made subject to a Money Transaction Offices has
system for monitoring been prepared. The CBS has started
and ensuring AML/CFT onsite inspections on
compliance with the MTOs in November 2013 and will
AML/CFT continue in 2014.
requirements.
Ii
The Act on Money Transaction
Offices came into force on October
29th 2012. This act governs the
supervision of money transfer
companies and money exchange
offices. In accordance with article
26 of this act, the Central Bank has
specific authority to issue
regulations on among other
AML/CFT. Article 28 authorizes
the Bank to share information with
local and foreign government
bodies as well as institutions that
are responsible for supervision on
the financial markets.

May 31, 2017

the State Advisory Council. Their
comments have been forwarded to
the ministry of Finance to be
implemented in the draft. Insider
trading and market manipulation
will be covered by this act.
also include the stock exchange and
securities firms.
The Act on Capital markets came
into effect on May 20th 2014.Art 7
places all market participants
iii. Surinamese authorities within the capital market under the
should consider supervision of the Bank.
regulating and Compliance with the provisions of
supervising the Stock the Act shall be monitored by the
exchange for Bank in the interest of a properly
AML/CFT purposes. functioning capital market.
According to art 10 of the act the
CBS may issue guidelines in
relation to the administrative and
management organization of a
stock brokerage firm or stock
exchange, including the financial

May 31, 2017
administration and the internal

control. The guidelines for the
operational management shall also
contain rules governing a sound
operational management which
will include among other
regulations regarding the
combating of money laundering
and financing of terrorism.
24. DNFBP - NC i. Suriname should In the MOT Act a new art. 22 ( sub Regulations related to the
regulation, effectively introduce as 1b) has been added, which appoint supervision of the Gaming
supervision and soon as possible an the Gaming Board as the Industry will be drafted.
monitoring AML/CFT-based
supervisory authority for casinos
regulation and and lotteries.
supervision of casinos
in accordance with As supervisory authority the
Recommendation 24. Gaming Board can issue
This includes the AML/CFT guidelines.
institution of a
regulatory body with
adequate powers and In the new art. 22 (sub 1c) the FIU
operational is appointed as the supervisory
independence, and authority for all other DNFBPs,
invested with sanctions and is authorized to issue
instruments that are AML/CFT guidelines.
effective, In line with the Suriname

May 31, 2017
proportionate and 2012, this legislation was adopted

dissuasive by Parliament on the 17th of July
ii. As for lawyers, 2012 and entered into force on the
Suriname should fully 9th of August 2012.
implement the Law on
Lawyers, a.o. by
making the Bar
Association
operational and
providing this entity
with all the instruments
described in the Law.
iii.
iv. In doing so, Suriname
should consider having
the Bar Association
issue one or more bar
decrees on AML/CFT
matters which
complement and
support the current
AML/CFT system set
out in the ID law and
the MOT Act.
Suriname should also
consider to remove the
current ministerial
authority set out in
article 34 of the Law on

May 31, 2017
Lawyers to annul a bar

decree within a given
period as this clearly
undermines the
independent status of
the Bar Association.
v. Suriname should
consider introducing
SRO-style bodies for
other (legal)
professionals, such as
civil notaries,
accountants and tax
advisors, with
mandatory
membership and
authority to regulate
and supervise these
professionals. Given
the total amount of for
example civil notaries
(currently 19 against a
legal maximum of 20)
this does seem quite
feasible.
25. Guidelines & PC i. Suriname is strongly For all service providers financial Closed 6th FuR
Feedback urged to introduce and non-financial guidelines were
guidelines for DNFBPs issued in October 2012 and part of

May 31, 2017
to assist them with the these guidelines addresses the area

implementation and of subjective indicators in which
compliance with their typologies for the services are
respective AML/CFT included.
requirements.
According to art. 4 sub 2 of the
MOT Act, the FIU will be able to
ii. The assessment team provide feedback to DNFBPs in
recommends the CBS to order to assist in applying national
work together with the AML/CFT measures and in
FIU and the Anti- detecting and reporting suspicious
Money Laundering transactions. Based on art. 4 sub 3
Commission in drafting the FIU is authorized to issue
guidelines for financial guidelines regarding the reporting
institutions (and
of UTRs.
DNFBPs) that give a
description of money Based on art. 5 sub 3 MOT Act, the
laundering and terrorist FIU can request the service
financing techniques provider to supply detailed
and methods. information within a certain period
of time.
Based on art. 6 and 8 MOT Act, the

FIU is required to provide
information once requested by
investigating and prosecuting
agencies. Such requests should be
channeled through the AG.

May 31, 2017
Based on art. 22 sub 2 of the act, the

FIU is authorized to issue
AML/CFT guidelines for the
DNFBPs.
Based on art. 4 sub 2, of the act, the

FIU will provide financial
institutions, DNFBPs, prosecutors,
investigators and the general public
with typologies and methodologies
in order to prevent and combat
ML/CFT.
9th of August 2012.
In October 2012 the FIU issued

guidelines for the financial and the
non-financial service providers
regarding the filing of UTRs and
subjects related to compliance and
supervision.

May 31, 2017
Institutional and
other measures
26. The FIU PC i. That the missing i. By Ministerial decree of the Closed 6th FuR
implementing legal Minister of Justice and Police, the
instruments be drafted organization chart of the Ministry
without further delay, of Justice and Police has been
so to consolidate the changed as of May 2011 and the
legal framework of the FIU has been identified as an
organization and independent institute.
functioning of the FIU; Art 2 sub 1 of the amended MOT
Act confirms the independent
status of the FIU.
ii
FIU personnel have been increased
from 4 to 12, including 4 analysts
ii. To substantially and 2 lawyers. The budget for the
increase the human and FIU has been incorporated in the
financial resourcing of budget of the Ministry of Justice
the FIU; and Police for the fiscal year 2012.

May 31, 2017
iii
Since September 2011 the FIU is
located in a new building situated in
the business area of Paramaribo.
iii. To move MOT to a The office space 170 m2 with a
location that ensures a 24/7 electronic security system.
secure conservation
iv
and management of the
sensitive information Since October 2009 a server (Local
and the safety of the Area Network) is in use by the FIU
staff; to store information. Sensitive and
confidential information are stored
in a secured database. Backups are
iv. To improve the IT made once a week.
security measures to
protect the sensitive
and confidential
information; v
The FIU has started with awareness
raising session for all service
providers since 2009, and will
continue.
v. That the sensitization Part of the sessions addresses
and education of all issues regarding typologies which
reporting entities are reported by service providers
should be substantially and documented in their UTR. By
enhanced by awareness doing so FIU is giving typology

May 31, 2017
raising sessions and feedback to service providers with

typology feedback, the aim to increase their perception
aimed at an increased of suspicious activities. For all
perception of service providers financial and
suspicious activity to be non-financial guidelines were
reported; issued in October 2012 and part of
these guidelines addresses the area
of subjective indicators in which
typologies for the services are
included.
As of June 27, 2014 FIU Suriname

has launched a website
(www.mot.sr) on which the
following information is available:
MOT legislation, annual reports.
vi
vi. To issue the necessary In the FIU guidelines as mentioned
guidance to the sector above explicitly in paragraph 3.2 a
stressing the time frame has been given for
importance of timely reporting of UTRs . When
reporting, particularly objective indicator is involved
of suspicious activity; reporting should

May 31, 2017
be done in 14 days and in case of

subjective indicator reporting
should be completed in 5 days.
vii
According to art. 7 of the MOT
Act, the FIU can, on a case to case
basis, requests information from
vii. To increase the quality law enforcement and governmental
of the analytical agencies, to be used in the
process by analytical process.
systematically
querying all accessible viii idem
sources, particularly the viii
law enforcement and
Based on art.13 of the MOT act, the
administrative data
FIU will institutionalize a forum of
(including tax
government agencies including
information);
supervisory bodies for the financial
and the non-financial sectors in
viii. To fully exploit all order to collect information related
possibilities of to ML/TF or any suspicious
information collection, grounds for these activities. The
particularly by having government agencies will include
the supervisory and police, immigration, customs,
Central Bank and the Gaming
board.

May 31, 2017
State authorities report

as provided by the Law;
ix. Finally, to intensify the
efforts for the analysts
to acquire better
knowledge and insight ix. Ongoing training of FIU staff.
in money laundering November 2009 orientation visit to
techniques and the FIU in Belgium, march 2010
schemes. visit to FIU N.A. November 2009
Tactical Analysis Course for FIU
personnel (by Egmont instructor
Mr.Dambruck)
In cooperation with the US
Treasury Department analysis and
supervision training will start in
October 2012.
27. Law PC The performance of the Interaction between Police (FOT)

enforcement AML/CFT effort should be and FIU has been improved.
authorities enhanced by:
Members of the Financial
i. A better interaction Investigative Team (FOT) have
between the FIU and participated in a training course
the police hosted by CIFAD in march 2012 in
Paramaribo. In

May 31, 2017
ii. A more efficient use of April 2012 two members of the

the information FOT team have attended a financial
supplied by the FIU investigating training seminar in
France.
iii. A reinforced focus on In cooperation with the US
the financial aspects Treasury Department financial
when investigating investigative training will start in
(proceeds generating) October 2012.
offences New dates for the above mentioned
training are set for April 2013.
There will also be a mixed setting
for FOT/MOT trainees.
28. Powers of C Closed

competent
authorities
29. Supervisors NC i. The CBS should have I Closed 6th FuR
the general power to According to Article 29 of the
compel production or Banking and Credit System
to obtain access to all Supervision Act CBS is authorized
records, documents or to conduct (on-site) inspections to
information relevant to ensure compliance with AML/CTF
monitoring regulations for all supervised
compliance. banks. Similar legislation has been
drafted to address the aspect of
inspection by CBS of MTOs and
MEOs.

May 31, 2017
ii
According to Articles 17 and 55 of
the Banking and Credit System
ii. The CBS should have
Supervision Act, CBS has the
the authority to
authority to enforce the AML/CTF
conduct inspections of
regulations and impose sanctions.
all relevant financial
institutions including ii
on-site inspection to The Supervision also regards
ensure compliance. AML/CFT guidelines issued
according to art.16 sub 1 of the
The supervisor should Bank and Credit System
iii.
Supervision Act.
have adequate powers
of enforcement and
sanction against iii
and their directors or In the MOT Act a new article 22 has
senior management for been added appointing the CBS as
failure to comply with AML supervisor of the financial
the AML/CFT sector. Under this legislation
requirements adequate powers of enforcement
and sanction for failure to comply
with AML/ CFT requirements is
given to CBS.
According to article 16, 17 and 19
sub 1 and 2 the Central Bank can
conduct AML/CFT on-site
inspections and impose sanctions

May 31, 2017
against credit institutions and their

directors for failure to comply with
AML/CFT guidelines issued by the
Central Bank.
In the new article 22 of the MOT
Act the CBS has been appointed as
the AML supervisory authority of
financial service providers. Under
this article the CBS is authorized to
give directives to the service
providers that fall under its
supervision for the purpose of
facilitating compliance with the
MOT Act. This article also enables
the supervisory authority i.c the
CBS to impose a maximum fine of
SRD 1 million for each
contravention on a service provider
that does not comply, or does not
comply on time, with the
obligations laid down in the
aforementioned directives of the
CBS.
According to article 1B of the Act

Penalization of Legal Entities of
September 5, 2002, regarding

May 31, 2017
detailed amendments to the

criminal code in connection with
the adoption of general provisions
the criminal liability of legal
persons, sanctions can applied for
AML/CFT violations to directors,
senior management and financial
institutions.
For 2013 three AML/CFT on-site
inspections of credit institutions are
scheduled of which two has been
conducted in April and July 2013
with assistance of the U.S. Treasury
Department, Office of Technical
Assistance. The inspection itself
involved five staff members plus
the advisor and covered 5 days
onsite plus a number of days in
preparation and post examination
analysis of gathered information
and preparation of a report.

ICRG/CFATF Action plan for
by Parliament, on the 17th of July

May 31, 2017

9th of August 2012.
30. Resources, PC i. To substantially FIU personnel have been increased Closed 5th FuR
integrity and increase the human and from 4 to 12, including 4 analysts
training financial resourcing of and 2 lawyers. The FIU is looking
the FIU; into increasing the staff.
The FIU staff has been increased to
a total of 17 members. For the
analysts in depth training has been
ii. The CBS should provided by the OTA of the USA
consider creating a team Treasury Department in 2014.
of examiners
specializing in The CBS will increase the number
AML/CFT measures of examiners. All examiners will be
that check financial trained in conducting AML/CFT
institutions compliance examinations by the US Treasury
with AML/CFT on an Department.
ongoing basis for all
On October 1st 2012 the Central
supervised entities.
Bank recruited 40 young trainees,
right out of the university, for
placement on a number of
departments in the Bank. 15 of

May 31, 2017
these trainees were allotted to the

Supervision Department. After the
initial orientation phase of 6 months
ending in March 2013, these
trainees will be assigned to the
different sections where they will
be trained in supervision of banks,
insurance companies, pension
funds and credit unions and other
aspects of supervisory work
including AML/CFT.
On November 5th2012 the
Governor of the CBS and the
Ambassador of the USA signed a
Terms of Reference for Technical
Assistance (TA). According to the
accompanying work plan the US
Treasury will train employees of
the Supervision Department, the
Legal Department and the Financial
Market Department in AML/CFT
supervision. The TA also includes
the drafting of AML/CFT manuals,
policies and procedures.
PP

May 31, 2017
Within the office of the Attorney

general, a senior prosecutor was
appointed in order to instruct and
guide FOT/KPS in the
investigation of ML/TF cases. In
2013, 9 persons will complete their
5 years period in order to become a
junior prosecutor.
They also receive training to
investigate and prosecute ML/TF
cases.
In 2014 nine junior prosecutors

joined the AGs office of which
two are also in the unit for
instructing financial investigations
including ML and TF cases. Also
in 2014 five new judges were
appointed. Part of the training of
the new judges includes financial
crime.
31. National co- LC i. Although the legal As of December 9th 2011 a AML Closed
operation mandate of the AML Steering Council was established
Commission does not consisting of the Minister of Justice
include the and Police, Minister of Finance and
coordination and the President of the Central Bank.

May 31, 2017
cooperation between This council constitutes a

the different competent partnership to strengthen the legal
authorities, in practice it framework for countering ML and
already goes some way TF and to strengthen the
in that direction. It supervision structure for the
could be an option to financial and non-financial sectors.
give this body a more
permanent and
structural character,
with extension of its
mandate to expressly
include coordination of
the AML/CFT effort
and streamlining the
cooperation between
the relevant actors, but
this matter is obviously
the sovereign decision
of the government. The
relatively small size of
the Suriname society is
already a facilitating
factor for an efficient
communication and
cooperative relation
between the relevant
actors.

May 31, 2017
32. Statistics NC Besides the criminalization of i. Closed 6th FuR

FT, local authorities should see A template to keep comprehensive
to it, that, as soon as there is an statistics on the number of
act criminalizing the FT, investigations, prosecutions and
comprehensive statistics be
kept on the number be formally distributed in August
investigations, prosecutions 2012 to the stakeholders: FIU,
and convictions for the act of Prosecutors office and the Central
FT Bank. (This is in line with the
i. The CBS should be given Suriname ICRG/CFATF Action
additional resources to be Plan for 2012).
allocated for AML/CFT i
supervision and maintain
statistics of the number Templates to keep comprehensive
of on-site inspections statistics on the number of
conducted and sanctions investigations, prosecutions,
applied. convictions and mutual legal
Investigative Team (FOT), Gaming
ii. The competent
authorities do not keep Board, Prosecutors office and the
annual statistics on the Central Bank.
number of cases and the
amount of property ii.
seized and confiscated
relating to ML, FT and The Central Bank will keep
statistics of AML/CFT on-site

May 31, 2017
criminal proceeds. No inspections. They will also keep

comprehensive statistics track of sanctions applied. The
are maintained on the Bank will also keep record of
number of cases and the formal request by law enforcement
amounts of property authorities and the decisions on
seized and confiscated such request.
relating to underlying
predicate offences.
iii. The CBS should keep
statistics on formal
requests for assistance
made or received by law
enforcement authorities
relating to money
laundering or financing
terrorism, including
whether the request was
granted or refused.
iv. The authorities should
endeavour to maintain
more detailed statistics
allowing them to assess
and monitor the
performance of the MLA
regime.

May 31, 2017
33. Legal persons NC Suriname should take According to art. 3a of the MOT LC 10th FuR
beneficial measures to prevent the Act, provisions are established
owners unlawful use of legal persons regarding a transparent system of
in relation to money identification of local and foreign
laundering and terrorist legal persons. Special provisions
financing. There should be have been made in art. 3a sub 4 for
adequate transparency the identification of religious
concerning the beneficial organization.
ownership and control of legal According to art. 6 jo. Art. 4 of the
persons. MOT Act, special attention is
The first time a foundation, required for business relationships
public limited company, co- and transactions regarding the
operative society / association identification of beneficial owners
or association is registered, the and control of legal persons.
information about the directors In line with the Suriname
is at hand and (most of the
ICRG/CFATF Action plan for
time) accurate. However there
is no information regarding the 2012, this legislation was adopted
(ultimate) beneficial owner by Parliament, on the 17th of July
and changes in directors or 2012 and entered into force on the
beneficial owners are not 9th of August 2012.
communicated with the
Based on art. 22 of the Bank and
registrars. Measures should be
Credit System Supervision Act it is
taken to ensure that the
prohibited to use bearer shares in
information with the different
credit institutions. Furthermore all
registrars is accurate and kept
shareholdings of 5% or more are
up to date.

May 31, 2017
Measures will have to be taken subject to permission from the

to prevent the misuse of bearer CBS.
shares for ML. Furthermore the Code of
Commerce has been amended and
in Art I sub a art.33 reads as
follows a Limited Liability
Company is a legal person with one
or more registered shares(O.G
2016 no.103).
34. Legal N/A
arrangements
beneficial
owners
International Co-
operation
35. Conventions PC i. Suriname should take i. LC 10th FuR
the necessary steps to
fully and effectively Several core principles of the
implement the Vienna Vienna Convention and the
Palermo convention have already
and Palermo
been incorporated in domestic law.
Conventions
ii.
ii. Suriname should The CFT legislation (O.G. 2011 no.
forthwith initiate the 96) is in accordance with the
accession procedure to recommendations of the UN/CFT
the CFT Convention Convention. ART. I A sub 8, of the

May 31, 2017
and take the necessary CFT legislation explicitly refer to

implementation steps. the UN convention.
ii.
On October 16th 2012 Parliament
adopted the Act concerning the
accession of the Republic of
Suriname to the International
Convention for the Suppression of
the financing of terrorism. This
legislation entered into force on
nd
iii. UN Res. 1267 and 1373 November 2 2012.
should be implemented
fully and without delay The instrument of accession to the
(see comments above UN/ CTF Convention has been
on SRIII). deposited and came into force for
Suriname on August 18th, 2013
The International Sanctions Act
came into force on May 21 2014
(O.G.2014 no.54) addressing the
aspects of freezing of funds related
to UN resolution 1267 and 1373.
A State Decree to give effect to
art.2 of this law has been drafted
and is subject to approval of the
Council of ministers.

May 31, 2017
iii.
Provisions have been incorporated
in the CFT Act (O.G. 2011 no. 96)
implementing UN Res. 1373. ART
IA sub 9, 71 a, 111a, 111b, 160 b,
188a, 228a, 228b of the CFT Act
(O.G. 2011 no. 96) i.a. criminalizes
the willful provision or collection,
directly of indirectly with the
intention that the funds will be used
in order to carry out terrorist acts.
Legislation regarding the

monitoring of the implementation
of international sanctions in the
International Sanctions Act (O.G.
2014 no.54) has been amended
appointing a Council on
International Sanctions with the
task of supervising all service
providers on compliance with the
provisions by or pursuant to this act
under art.2.
See attachment: International
Sanction Act (O.G 2016 no.31).,

May 31, 2017
art.1,4a,5,5a,5b,5c,5d,5e,6a,6b,6c,
7,7a,7b and 7c.
A State Decree (O.G.2016 no 34)

implementing art.2 section 1 of the
International Sanctions Act,
complying with the international
obligations as contained in
Resolution 1267, 1333, 1452, 1735,
1988, 1989, 2160, 2161 and 2170 of
the Security Council of the United
Nations, has been approved on the
29th of February 2016.
See attachment: State Decree on
International Sanctions, art. 1 to
art.8.
The State Decree (O.G. 2016 no

131), further implementing Art 2
sub 1 and sub 8 of the International
sanction Act, introduces procedures
for the listing, de-listing and
freezing and unfreezing of funds of
natural and legal persons, entities or
bodies.

May 31, 2017
By Ministerial Decree procedures

will be laid down for the adoption
and the termination of anti-
terrorism freezing measures that
has been taken against natural and
legal persons, entities or bodies
including the listing on and de-
listing of the sanction list. These
procedures are with regard to the
list of persons and entities as
established and maintained by the
UN Sanction Committees as well as
the national sanctions list which
also includes the persons, bodies
and entities designated by request
of foreign states.
(See attachment)
The WOTS Act has passed
Parliament on Thursday, 13 th
October, 2016 and publication in
the Official Gazette is now
pending.
WOTS Act was published in O.G.

2016 no. 132. See attached copy.

May 31, 2017
36. Mutual legal C Closed

assistance
(MLA)
37. Dual criminality PC i. In order to enhance the i. Closed 6th FuR

quality and
comprehensiveness of In the Act penalizing Terrorism and
its MLA system, the the Financing of Terrorism (O.G.
2011 no. 96) in general all
Suriname authorities
categories of predicate offences,
should endeavour to related to money laundering are
complete their penal applicable to the financing of
legislation with a terrorism (art. I C sub art. 71a). This
speedy introduction of also includes acts in preparation of
the missing designated activities related to terrorism.
predicate offences The dual criminality principle is
(insider trading and addressed in the Extradition act of
stock market June 10th 1983 (O.G.1983no.52)
manipulation) and the
Article 3
offence of terrorism 1. Extradition can only be
financing, so as to avoid granted for the benefit of:
all prohibitions a. an investigation by the
resulting from the dual
authorities of the
criminality principle.

May 31, 2017
requesting State in respect

of the presumption that the
person to be extradited is
guilty of a criminal act for
which both the law of the
ii. The narrow and requesting State as that of
legalistic interpretation Suriname impose a
of the dual criminality punishment of one year or
principle should be put longer.
to the test and efforts b. the execution of a court
should be made to try sentence of four mounts or
and create longer of the person to be
jurisprudence which extradited for a criminal act
would bring the as mentioned under a.
application of this
(rightful) principle in 2. for the purposes of the
line with the broader preceding paragraph, a to
international standard, Surinamese law offence
which only requires the include a criminal act
underlying conduct to which has been infringed
be criminalized by both upon on the legal order of
countries. Legal the requesting State while
certainty on the
under the Surinamese law a
capability to execute
punishable infringement of
foreign confiscation
the rule of law is the same.
orders should be

May 31, 2017
ensured, if necessary
through specific CBS is drafting legislation
legislation. regarding the supervision on
capital markets in this legislation
insider trading and market
manipulation are criminalized
according to the Suriname Action
Plan this legislation should come
into force before the end of the
year.

the State Advisory Council. Their
comments have been forwarded to
the ministry of Finance to be
implemented in the draft. Insider
trading and market manipulation
will be covered by this act.
into effect on May 21th 2014

May 31, 2017
38. MLA on PC i. In order to enhance the According to art. 71a of O.G. 2011 Closed 6th FuR
confiscation and quality and no. 96, seizure and confiscation of
freezing comprehensiveness of goods and values, related to all
its MLA system, the designated predicate offences,
Suriname authorities including TF, has been made
should endeavor to possible.
complete their penal
legislation with a
speedy introduction of
the missing designated Provisional and confiscation
predicate offences measures also related to TF are
(insider trading and addressed, respectively in art. 82
and 82a of the Criminal Proceeding
stock market
Code, and in art. 50, 50a, 50b and
manipulation) and the
50c of the Penal Code as amended
offence of terrorism in O.G. 2002 no. 67.
financing, so as to avoid
all prohibitions The Act on Capital markets came
into effect on May 21th 2014. Art
resulting from the dual
19 and 21 respectively, criminalize
criminality principle. insider trading and market
manipulation

May 31, 2017
ii. The narrow and

legalistic interpretation
of the dual criminality
principle should be put
to the test and efforts
should be made to try
and create
jurisprudence which
would bring the
application of this
(rightful) principle in
line with the broader
international standard,
which only requires the
underlying conduct to
be criminalized by both
countries. Legal
certainty on the
capability to execute
foreign confiscation
orders should be
ensured, if necessary
through specific
legislation.
39. Extradition LC i. The deficiencies Money laundering and terrorist Closed
financing are extraditable offences.
established in respect of

May 31, 2017
the criminalization of Nationals who committed ML/TF

all designated predicate crimes abroad cannot be extradited.
offences and terrorism Based on article 466a of the
financing should be Criminal Proceeding Code, the AG
remedied forthwith. can request the competent judicial
authorities of the foreign country to
Also the restrictive
transfer the ML/TF cases for the
interpretation of the purpose of prosecution.
dual criminality
principle should be
subject to
reconsideration.

May 31, 2017
40. Other forms of PC FIU Closed 9th FuR

co-operation i. In order for MOT
Suriname to legally and ii.
fully become a player in Legislation amending art. 9 of the
the international FIU MOT Act, regarding the sharing of
forum and to comply information, both, locally and
with the present internationally was adopted by
standards, it is Parliament, on the 17th of July 2012
recommended that: and entered into force on the 9th of
August 2012.
ii. The treaty condition
should be discarded and
replaced by the generally
accepted rule of
iii.
information exchange
Legislation amending art. 9 sub 2
with its counterparts,
of the MOT act, in order to
based on reciprocity and
maintain a line of communication
the Egmont Principles of
with foreign FIUs, based on a
Information exchange.
MOU in order to share data
Ideally such exchange
was adopted by Parliament, on the
should be allowed on an
ad hoc basis or, if
deemed necessary, on the
basis of a bilateral
iv.
agreement between
Conditions regarding the
FIUs;
confidentiality status of the
iii. The Law should exchanged information will be
expressly allow MOT to included in the MOU.

May 31, 2017
collect information
outside its register at the
request of a counterpart v.
FIU. One simple and The FIU is now located in a new
adequate way to realize building with an office space of
this is to put such foreign 170 square meters, with a 24/7
request legally at par electronic security system in the
with a disclosure, which business area in the capital of
would automatically Paramaribo.
bring them under the Additional IT security measures
regime of art. 5 and 7 of had been implemented to protect
the MOT Act; sensitive and confidential data.
iv. The confidentiality status
vi.
of the exchanged
In art. III sub C and D of the CFT
information should be
legislation (O.G. 2011 no. 96),
expressly provided for to
UTRs should be filed once a
protect it from undue
transaction is, or can be related to
access or dissemination;
TF.
v. The (physical) protection vii

of the MOT data-base The Banking and Credit System
and its offices be Supervision Act (O.G. 2011 no.
upgraded; 155), which entered into force on
November 23rd 2011 creates a
legal basis for information
exchange between CBS and
counterpart supervisors based on a
MMOU.

May 31, 2017
The Central Bank entered into an

vi. The processing of TF
information exchange, co-
related disclosures
operation and consultation
should be brought within
agreement (MMOU) with the
the assignment of the
Caribbean Group of Banking
FIU as soon as possible,
Supervisors in July 2012.
which would also
increase the chance of
As stated in the 6th FuR the gap
MOT acceding to the
relative to the third assessor
Egmont Group and its
recommendation that The law
ESW.
should expressly allow MOT to
Supervisor collect information outside its
vii. A legal basis should be register at the request of a
provided for information counterpart FIU.
exchange between the
CBS and counterpart Art 9 sub 2 of the MOT Act states
supervisors, by way of that maintaining contact with and
MOUs or otherwise. exchanging data from the FIUS
register to agencies outside of
Suriname whose duties are
comparable to those of the FIUS
will only take place on the basis of
a treaty/convention or a
Memorandum of Understanding.
The conditions under which data is
provided are laid down in the
treaty/convention or in the
Memorandum of Understanding.

May 31, 2017
Legislation amending art.9 of the

MOT Act (O.G.2016 no.33), which
expressly allows MOT to collect
information outside its register
from governmental, financial- and
non - financial institutions and
other public sources of
information, was adopted by
Parliament on the 29th of February
3rd of March 2016.
See attachment: Disclosure of
Unusual Transactions Act (MOT
Act), under B, art.9 section 3)
Nine Special Rating

Recommendations
SR.I Implement NC i. Suriname should take i. LC 10th FuR

UN instruments the necessary steps to
fully and effectively Several core principles of the
implement the Vienna Vienna Convention and the
Palermo Convention have been
and Palermo
incorporated in domestic law.
Conventions

May 31, 2017
ii.
ii. Suriname should The International Sanctions Act
forthwith initiate the came into force on May 21 2014
accession procedure to (O.G.2014 no.54) addressing the
the CFT Convention aspects of freezing of funds related
and take the necessary to UN resolution 1267 and 1373.
implementation steps. A State Decree to give effect to
iii. UN Res. 1267 and 1373 Council of ministers.
should be implemented
fully and without delay
(see comments above ii.
on SRIII). On October 16th 2012 Parliament
accession of the Republic of
Suriname to the International
Convention for the Suppression of
November 2nd 2012.
The instrument of accession to the
UN/ CTF Convention has been
deposited and came into force for
Suriname on August 18th, 2013

May 31, 2017
iii.
to implement UN Res. 1373. ART
IA sub 9, 71 a, 111a, 111b, 160 b,
(O.G. 2011 no. 96) i.a. criminalizes
the willful provision or collection,
directly of indirectly with the
intention that the funds will be used
in order to carry out terrorist acts.
Legislation regarding the

monitoring of the implementation
of international sanctions in the
International Sanctions Act (O.G.
2014 no.54) has been amended
appointing a Council on
International Sanctions with the
task of supervising all service
providers on compliance with the
provisions by or pursuant to this act
under art.2.
See attachment: International
Sanction Act (O.G 2016 no.31).,

May 31, 2017
art.1,4a,5,5a,5b,5c,5d,5e,6a,6b,6c,
7,7a,7b and 7c.
A State Decree (O.G.2016 no 34)

implementing art.2 section 1 of the
International Sanctions Act,
complying with the international
obligations as contained in
Resolution 1267, 1333, 1452, 1735,
1988, 1989, 2160, 2161 and 2170 of
the Security Council of the United
Nations, has been approved on the
International Sanctions, art. 1 to
art.8.
bodies.

May 31, 2017

of foreign states.
(See attachment)
pending.
SR.II Criminalize NC i. Besides the The CFT legislation (O.G. 2011 Closed 4th FuR
terrorist financing criminalization of FT, no. 96) also amendments were
local authorities should made regarding the Fire arms Act
see to it, that, as soon as and the act regarding suspicious

May 31, 2017
there is an act transactions. In general all

criminalizing the FT, categories of predicate offences,
comprehensive related to money laundering are
statistics be kept on the applicable to the financing of
number investigations, terrorism.
prosecutions and A template to keep comprehensive
convictions for the act statistics on the number of
of FT investigations, prosecutions and
Prosecutors office and the Central
Bank. (This is in line with the
Plan for 2012)
Investigative Team (FOT), Gaming
Board, Prosecutors office and the
Central Bank.

May 31, 2017
SR.III Freeze and NC i. None of the criteria of i. LC 10th FuR

confiscate Special The CFT legislation (OG 2011 no.
terrorist Recommendation III 96) in art. I and II, makes
assets are met by Suriname. confiscation of assets related to
Many of the people the financing of terrorism,
interviewed did not possible.
even know of the
existence of UN
Security Council
Resolutions 1267
(1999) and 1373 (2001) ii.
and there implications, Provisions have been incorporated
nor did they have any in the CFT Act (O.G. 2011 no. 96)
information regarding to implement UN Res. 1373. ART
the Best Practice Paper. IA sub 9, 71 a, 111a, 111b, 160 b,
ii. The Suriname (O.G. 2011 no. 96) i.a.
authorities should criminalizes the willful provision
endeavor to introduce or collection, directly or indirectly
the appropriate with the intention that the funds
legislative measures will be used in order to carry out
effectively terrorist acts.
implementing the
relevant UN Draft legislation addressing the
Resolutions and freezing regime related to UN
establishing an resolution 1373 was approved by
adequate freezing the State Advisory Council and
regime in respect of will be sent to Parliament.

May 31, 2017
assets suspected to be The International Sanction act has

terrorism related. been enacted (O.G. 2014 no54) in
order to comply with conventions
or binding resolutions of
international law organizations,
e.g. UN security council
resolution 1267 and 1373. This act
also provides for a freezing
regime in respect of assets
suspected to be terrorism related.
The International Sanctions Act

came into force on May 21 2014
(O.G.2014 no.54) addressing the
aspects of freezing of funds related
to UN resolution 1267 and 1373.
A State Decree to give effect to
Council of ministers.
Legislation regarding the freezing

regime has been amended,
entrusting the Council on
International Sanctions with
announcement of the updates of the
freezing list on its website. See

May 31, 2017
attachment: International Sanction

Act (O.G 2016 no.31) art.5b sub 2.
State Decree, O.G.2016 no

34)obligates that all balances and
other means belonging to Al-
Qaeda, the Taliban of Afghanistan,
ISIL, ANF, members or
representatives of named
organizations and also other with
said organizations associated
natural persons or legal bodies,
entities or bodies as referred to in
the Resolutions 1267, 1333, 1373,
1452, 1735, 1988, 1989, 2160,
2161 and 2170 of the Security
Council and mentioned in the annex
pertaining to this decree, shall be
frozen, has been approved on the
International Sanctions (O.G. 2016
no. 34), art. 2 sub 1.

May 31, 2017

bodies.
of foreign states.
(See attachment)

pending.

May 31, 2017


May 31, 2017
SR.IV Suspicious NC i. The reporting i Closed 6th FuR

transaction reporting obligation under the Criminalization of insider trading
MOT Act should cover and market manipulation in the
transactions related to capital Market Act will qualify
insider trading and
these offenses as predicate offences
market manipulation. with the obligation to report these
offences to the FIU.
into effect on May 21th 2014
In the State Decree on Unusual
Transaction (SDIUT) all services
regarding securities transactions are
listed in Annex A. Institutions need
to determine whether a conducted
or intended transaction is unusual
within the meaning of the law when
rendering these services. Art 12 of
the MOT ACT requires that service
providers that discover facts during
the performance of their duties
which point to money laundering
and financing of terrorism are
obligated, with due observance of
the indicators laid down by SDIUT
to immediately disclose an effected
or intended unusual transaction in

May 31, 2017
writing -digitally or non-digitally-

to the FIU.
ii.
Requirements for Financial
institutions to report UTRs to the
FIU on grounds based on TF are the
same as for ML as stated in art III
of the CFT legislation (OG 2011
ii. The reporting duty no. 96).
needs to be explicitly in
the law to include all
funds where there are
reasonable grounds to
suspect or they are iii.
suspected to be linked In article I sub C of the CFT
or related to, or to be legislation amending the Penal
used for terrorism, for Code and the MOT Act(O.G.
terrorist acts, or by 2011no. 96), an attempt and
terrorist organizations preparation act of ML / TF has been
or those who finance penalized.
terrorism. The draft State Decree on
iii. The assessment team Indicators of Unusual Transactions
advises to include in (SDIUT) has been forwarded to the
the State Decree on council of Ministers for approval.
Unusual Transactions After approval it will be sent to the
the requirement to also State Advisory Council and based
on their advice it will be enacted

May 31, 2017
report attempted through publication in the State

unusual transactions Gazette.
The State Decree on Indicators of
Unusual Transactions (SDIUT) has
iv. The financial
been approved (O.G.2013 no.148)
institutions that choose
and entered into force on August
to use an UTR-
15th, 2013.
interface for reporting
purposes, should be
obliged to improve the iv.
quality of the UTRs as
soon as possible and in Legislation amending art. 12 of the
such a way that the MOT Act, with the obligation for
disclosures contain all disclosers containing information
information as as prescribed by article 12.2. was
th
prescribed by article adopted by Parliament, on the 17
12.2. of the MOT Act. of July 2012 and entered into force
on the 9th of August 2012.
v. The authorities should
consider whether the v. Sub 2 of art. 12, where the
obligation to report reporting requirements are
unusual transactions stipulated was amended, obligating
without delay is financial institutions to improve
sustainable. the quality of the UTRs.
vi. The FIU and other vi.

competent authorities
should make an Legislation amending the MOT
Act, adding a new art 22, sub 1c,

May 31, 2017
inventory to identify all giving the MOT the authority to

financial institutions supervise the DNFBPs, and apply
and DNFBPs that have sanctions in case of none
a reporting compliance as mentioned in art. 22
requirement, reach out sub 3, was adopted by Parliament,
to these parties and on the 17th of July 2012 and entered
apply sanctions in case into force on the 9th of August
of non-compliance. 2012.
vii. The FIU and other

competent authorities
should raise awareness
and enhance the
sensitivity of all
and DNFBPs regarding
money laundering and
terrorist financing
risks.
SR.V International NC
i. The deficiencies Mutual legal assistance can be Closed 7th FuR
cooperation
established in respect of requested or provided in all
the criminalization of criminal cases, including ML/TF,
all designated predicate as stipulated in art. 466a (ART I B,
offences and terrorism O.G. 2002 no. 71)

May 31, 2017
financing should be
remedied forthwith. Draft legislation addressing the
Also the restrictive freezing regime related to UN
interpretation of the resolution 1373 was approved by
dual criminality the State Advisory Council and will
principle should be be sent to Parliament.
subject to The International Sanction act has
reconsideration. been enacted (O.G. 2014 no 54) in
order to comply with conventions
or binding resolutions of
international law organizations,
e.g. UN security council
resolution 1267 and 1373. This act
also provides for a freezing
regime in respect of assets
suspected to be terrorism related.
SR VI AML NC i. A competent authority Closed 6th FuR

i
requirements for should be designated to
money/value register or licence The Act concerning the
transfer services MTCs and be Supervision of Money Transaction
responsible for Offices which includes money
ensuring compliance transfer offices (MTOs) and money
with licensing and/or exchange offices (MEOs) has been
registration adopted by Parliament on October
requirements. 29th 2012. (O.G. 2012 no 170).

May 31, 2017
Under the new legislation the CBS

is the sole licensing authority for
MTOs and MEOs.
ii
Based on art. I sub A (13) of the
MOT Act, unusual transactions are
those listed in the State decree
ii. A system for MOT indicators. This legislation
monitoring MTCs was adopted by Parliament, on the
ensuring that they 17th of July 2012 and entered into
comply with the FATF force on the 9th of August 2012.
Recommendations
should be iv
implemented. The The CBS has issued in April 2012,
mission also new AML/CTF regulations for the
recommends that the financial sector in line with the
CBS issues the recommendations of the MER.
AML/CFT Guidelines
to MTCs that indicate
circumstances in which
a transaction might be
considered as
unusual.
iii. MTCs should be

required to maintain a
current list of its agents
and sub-agents, which
must be made available

May 31, 2017
to the CBS and the

Foreign Exchange
Commission.
iv. The measures set out in

the Best Practices
Paper for SR.VI should
be implemented and
Suriname authorities
should take FATF R.
17 into account when
introducing system for
monitoring money
transfer companies.
SR VII Wire NC The CBS has issued in April 2012, LC 10th FuR
i. Suriname should issue a
transfer rules new AML/CTF regulations for the
law or regulation to
implement the financial sector in line with the
requirements of Special recommendations of the MER,
Recommendation VII. with regard to CDD measures for
wire transfers. These include the
requirement for accurate and
meaningful originator information
on funds transfer and enhanced
scrutiny of and monitoring for
suspicious activity funds transfers
which do not contain complete
originator information.

May 31, 2017
Amended CBS AML/CFT

2015.
The CDD requirements in
paragraph 1 have been expanded
with a special section on wire
transfer rules.
April 1, 2015.
(paragraph I: Electronic Transfers
of Funds). Requirements for
electronic transfers are:
- with all electronic transfers
of funds that conform with
the threshold amounts
specified in the Decree, it is
required of the financial
institution which will
execute the transaction that
they request and record the
details of the person from
whom the funds originate
(the payer), in particular:

May 31, 2017
name, account number (or

reference number) and
address. The customer
identification number or
national identity number
may be substituted for his
address;
- with cross-border
electronic transfers of
funds, the financial
institution which will
execute the transaction
must have at its disposal
complete information
regarding the payer and the
payee. In the event that the
payer's account number is
lacking, the financial
institution can substitute
for this the identification
code which can trace the
transaction back to the
payer;
- the basic information
regarding the payer which
is to be appended to
transfers of funds should be
immediately available for
inspection by competent

May 31, 2017
authorities who are charged

with the combating of
money laundering and the
financing of terrorism;
- if the financial institution
has no direct relationship
with the receiving financial
institution and the
transaction is carried out
via correspondent banks,
then there is a question of
two components: namely,
the one part concerns
information between the
financial institution which
authorises the payment and
the receiving institution,
and the other part concerns
the information exchange
between the correspondent
banks. With the electronic
transfer of funds,
information regarding the
payer should be appended
and the correspondent bank
is to ensure that all
information received
concerning the person,
which has been appended

May 31, 2017
to an electronic transfer of
funds, remains with that
credit transfer;
- on the basis of a risk
evaluation, the receiving
financial institution should
demonstrate particular
alertness when information
regarding the payer is
lacking or is incomplete. In
the event that the required
payer is incomplete, the
receiving institution refuses
to execute the credit
transfer or makes a request
for the complete
payer. If a financial
institution regularly fails to
provide the required
payer, the receiving
institution takes measures,
which may consist of the
sending of warnings or the
imposition of deadlines,
before deciding to refuse
all future credit transfers

May 31, 2017
from this institution or

deciding either to restrict or
to terminate its business
relationship with this
institution. The receiving
financial institution reports
this fact to the FIU.
The CBS AML/CFT Directive has

been amended on October 13, 2016.
Under the special section on
Electronic transfers of Funds in
paragraph 1 of the amended
directive financial institutions are
required to record certain data for
both cross border and domestic
transactions. Cross border wire
transfers below a minimum of
USD/EUR 1000,- should include
the name of the originator, the name
of the beneficiary and an account
number for each, or a unique
transaction reference number.
Cross-border wire transfers higher
than USD/EUR 1,000 should
always contain the following
accompanying information:
(a) the name of the originator;

May 31, 2017
(b) the originator account number

where such an account is used to
process the
transaction;
(c) the originators address, or
national identity number, or
customer identification
number , or date and place of birth;
(d) the name of the beneficiary;
(e) and the beneficiary account
number where such an account is
used to process the
transaction.
In the absence of an account, a

unique transaction reference
number should be included
which permits traceability of the
transaction.
Information accompanying
domestic wire transfers should also
include originator information
as indicated for cross-border wire
transfers, unless this information
can be made available to

May 31, 2017
financial institution of the

beneficiary and appropriate
authorities by other means. In this
latter
case, the ordering financial
institution need only include the
account number or a unique
transaction reference number,
provided that this number or
identifier will permit the
transaction to be traced back to the
originator or the beneficiary.
The responsibilities of the ordering,
intermediary and beneficiary
financial institutions are also
included in the amended directive.
(See Page 11 of the CBS Directive

on AML/CFT October 2016).
Ordering financial institution:
- The ordering financial
institution should ensure
that qualifying wire
transfers contain required
and accurate originator
information, and required
beneficiary information;

May 31, 2017

institution should ensure
that cross-border wire
transfers below any
applicable threshold contain
the name of the originator
and the name of the
beneficiary and an account
number for each, or a
unique transaction
reference number;
institution should maintain
all originator and
beneficiary information
collected;
institution should not be
allowed to execute the wire
transfer if it does not
comply with the
requirements specified
above.

May 31, 2017
ii. For cross-border wire Closed

transfers of EUR/USD
1000 or more the
ordering financial
institution should be
required to include full
originator information.
iii. For domestic wire

transfers of EUR/USD
1000 or more the Closed
ordering financial
institution should be
required to include full
originator information
or only include the
originators account
number.
iv. Each intermediary and

beneficiary financial
institution should be iv.1 Considered to be CLOSED.
required to ensure that See CBS Directive on AML/CFT

May 31, 2017
all originator
October 2016, page 12: Where
information is
technical limitations prevent the
transmitted with the required originator or beneficiary
transfer. Where information accompanying a cross-
technical limitationsborder wire transfer from
prevent full origination remaining with a related domestic
information, a record wire transfer, a record should be
must be kept for five kept, for at least seven years, by
years by the receiving the receiving intermediary
intermediary financial financial institution of all the
institution of all the information received from the
information received ordering financial institution or
from the orderinganother intermediary financial
financial institution institution.
An intermediary financial
institution should take reasonable
measures to identify cross-border
wire transfers that lack required
originator information or required
beneficiary information. Such
v. Effective risk-based measures should be consistent with
procedures for straight-through processing.
identifying and
handling wire transfer
Closed

May 31, 2017
vi. Countries should have

measures in place to
effectively monitor the
compliance of financial
institutions with rules
and regulations. Considered to be Closed
CBS Directive on AML/CFT of
October 2016 and also the CBS
Manual for Off-site and On-site
vii. Examinations, AML and CFT
(January 2013), page 37.
Closed
SR.VIII Non-profit NC i. Suriname should i

organisations forthwith initiate the
On October 16th 2012 Parliament
accession procedure to
the CFT Convention accession of the Republic of
and take the necessary Suriname to the International
implementation steps. Convention for the Suppression of

May 31, 2017

ii. UN Res. 1267 and 1373 November 2nd 2012.
should be implemented The instrument of accession to the
fully and without delay UN/ CTF Convention has been
(see comments above deposited and came into force for
on SRIII). Suriname on August 18th, 2013
Draft Act to incorporate NPOs in
both the MOT and WID act has
been finalized in order to forward to
the Council of Ministers.
Amended CBS AML/CFT

2015.
A new paragraph 9 has been added
to the regulation that deals with
NPOs. Financial institutions are
obligated to assess the risk
associated with NPOs and to keep
detailed records of the NPO and its
activities.
ii.

May 31, 2017

to implement UN Res. 1373.
ART IA sub 9, 71 a, 111a, 111b,
160 b, 188a, 228a, 228b of the CFT
Act (O.G. 2011 no. 96) i.a.
criminalizes the willful provision or
collection, directly or indirectly
with the intention that the funds
will be used in order to carry out
terrorist activities.
ii
recommendations of the MER that
also address the implementation of
UN resolution 1267 and 1373.
In paragraph 8 of the AML/CFT

regulations issued by the Central
Bank in 2012 financial institutions
are required to take all necessary
measures with regard to the
prevention of misuse of NPOs
such as foundations and charitable
organisations by terrorists or by
terrorist organisations. These

May 31, 2017
regulations were issued in

accordance with the Banking and
Credit System Supervision Act of
2011.
Legislation amending art.I of the

WID Act (O.G. 2016 no. 32),
requires non profit organizations
to perform enhanced customer due
diligence when receiving,
supplying, subsidizing, collecting
and transferring financial means,
29th of February 2016 and entered
into force on the 3rd of March 2016.
See attachment: Act on the
Service Providers (WID Act), art.I)
SR.IX Cross Border NC i. The Suriname The Ministry of Foreign Affairs, in Closed 9th FuR
Declaration & authorities should collaboration with all stakeholders,
Disclosure decide on the choice will conduct a pilot phase in
between a disclosure or November 2012, after which it will
a declaration system become official.
for cross-border This system will detect incoming
transportation of and outgoing passengers and will
currency or bearer enable blacklisting, giving the
negotiable instruments Government tools to address

May 31, 2017
and put in place such threats in the area of terrorism and

system aimed at illegal trafficking of immigrants.
discovering criminal or The Ministry is now busy with the
terrorist related assets drafting of an Embarkation Card in
without delay. which the money laundering aspect
will be tackled.
On the 19th November 2012 the

Border Management System was
officially introduced on 4 border
crossing points. This system
registers outgoing passengers and
the authenticity of passports can
also be detected. Currently the
ministry of Foreign Affairs is
negotiating with Interpol and
IMPACS/JRCC to connect the
systems, the watch list and the
APIS system. The Military police
is discussing the issue of
embarkation/disembarkation cards
with the ministry of Justice and
Police and Customs.
The order regarding the declaration

form came into force on January
22th, 2015. See attachment

May 31, 2017
Custom declaration form has been

introduced and this
recommendation is considered to
be closed.

Cfatf Fur Suriname 11 PP

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Cfatf Fur Suriname 11 PP

Uploaded by

Copyright:

Available Formats

CARIBBEAN FINANCIAL

ACTION TASK FORCE

Suriname Eleventh Follow-up Report

Summary: Detailed exit report of Suriname

Meeting Date: May 31th 2017

Port of Spain, Trinidad and Tobago

2017 CFATF. All rights reserved.

Caribbean Financial Action Task Force (CFATF) Page 2 of 171

Recommendation 23 overall conclusion ....................................................................... 23

Caribbean Financial Action Task Force (CFATF) Page 3 of 171

SURINAME: ELEVENTH FOLLOW-UP REPORT UPDATE AND FULL ANALYSIS

The Legal and Regulatory Framework

Caribbean Financial Action Task Force (CFATF) Page 4 of 171

Table 1: Ratings for Core, Key and other Recommendations

PARTIALLY COMPLIANT (PC) NON-COMPLIANT (NC)

Caribbean Financial Action Task Force (CFATF) Page 5 of 171

II. MAIN CONCLUSION AND RECOMMENDATIONS TO THE PLENARY

9. Recommendation 13: The criminalization of all designated categories of offences,

Caribbean Financial Action Task Force (CFATF) Page 6 of 171

Caribbean Financial Action Task Force (CFATF) Page 7 of 171

Caribbean Financial Action Task Force (CFATF) Page 8 of 171

III. OVERVIEW OF PROGRESS MADE BY SURINAME

Caribbean Financial Action Task Force (CFATF) Page 9 of 171

Caribbean Financial Action Task Force (CFATF) Page 10 of 171

IV. DETAILED ANALYSIS OF COMPLIANCE WITH THE CORE

Caribbean Financial Action Task Force (CFATF) Page 11 of 171

R. 1 (Deficiency 2): It is virtually impossible to do any assertion with regards to the

38. The maintenance and availability of comprehensive statistics are addressed at

R. 1 (Deficiency 3): Evidentiary requirements for autonomous ML still untested

Caribbean Financial Action Task Force (CFATF) Page 12 of 171

Recommendation 1- overall conclusion

CBS Directives as Other Enforceable means (OEM)

Caribbean Financial Action Task Force (CFATF) Page 13 of 171

R.5 (Deficiency 2) The definition of financial activities should be updated in

Caribbean Financial Action Task Force (CFATF) Page 14 of 171

Caribbean Financial Action Task Force (CFATF) Page 15 of 171

R.5 (Deficiency 8): No specific requirement to perform ongoing due diligence on

R.5 (Deficiency 10): There should be some consideration/assessment made based on

Caribbean Financial Action Task Force (CFATF) Page 16 of 171

Recommendation 5 overall conclusion

57. Legislative action has resulted in Suriname significantly addressing 10 of the 13

Recommendation 10 overall conclusion

Caribbean Financial Action Task Force (CFATF) Page 17 of 171

R.13 (Deficiency 2): There is no requirement to report suspicious transactions

62. As noted in the analysis of Recommendation 1, Suriname criminalized terrorism by

Caribbean Financial Action Task Force (CFATF) Page 18 of 171

66. On November 7, 2012 Suriname forwarded a list of non-service providers in the

Caribbean Financial Action Task Force (CFATF) Page 19 of 171

Recommendation 13 overall conclusion

Special Recommendation II overall conclusion

Special Recommendation IV overall conclusion

Caribbean Financial Action Task Force (CFATF) Page 20 of 171

V. DETAILED ANALYSIS OF COMPLIANCE WITH THE KEY

77. The maintenance and availability of comprehensive statistics are addressed at

Recommendation 3 overall conclusion

Caribbean Financial Action Task Force (CFATF) Page 21 of 171

1. the provision of such information is not or is not expected within reason to be

Recommendation 4 overall conclusion

R. 23 (Deficiency 1): Relevant supervisory authority has not been designated as

Caribbean Financial Action Task Force (CFATF) Page 22 of 171

Supervision and Control Institute as Supervisory Authority in so far as gaming providers

85. R. 23 (Deficiency 3): Surinamese authorities should consider regulating and

Recommendation 23 overall conclusion